Privacy Policy


 1. Introduction


Effective date: May 22, 2018

Sofema Aviation Services ("us", "we", or "our") operates the https://www.sassofia.com and https://www.sofemaonline.com websites (the "Service").

This page informs You of our policies regarding the collection, use, and disclosure of personal data when You use our Service and the choices You have associated with that data.

Throughout this document any reference to Sofema Aviation Services and Sofema Online may be considered as mutually applicable in respect of all obligations, requirements and business process management.

Sofema Aviation Services provides EASA Compliant Regulatory and Vocational Training through www.sassofia.com and www.sofemaonline.com

At Sofema Aviation Services the privacy and security of our customers, respondents and visitors are of paramount importance. Sofema Aviation Services is committed to protecting the data You share with us. This privacy policy explains how Sofema Aviation Services processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of its website and platform.

Therefore, our Sofema Aviation Services publishes this Privacy Policy, in accordance with the:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), in use since May 25, 2018 in Republic of Bulgaria and all EU member states, Legal framework for the protection of personal data in the Republic of Bulgaria and the European Union and European best practice.

Please note that by registering on our website and connected services, sending an inquiry, signing a contract with Sofema Aviation Services or through direct contact, You voluntarily agree to share Your data or data of the Company You represent with Sofema Aviation Services.

By doing so, You also agree for this data to be used in order to protect personal interests in all transactions contracted with Sofema Aviation Services.

1.1 Definitions


Service

Service is the https://www.sassofia.com/ and https://www.sofemaonline.com/ websites operated by Sofema Aviation Services.

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small pieces of data stored on Your device (computer or mobile device).

Data Protection Officer

Data Protection Officer means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process Your data more effectively.

For the purpose of this Privacy Policy, we are a Data Controller and a Data Processor of Your Personal Data.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to You.

1.2 Classification of Persons Contacting Sofema Aviation Services / Sofema Online


User

A user is any person who has cause to engage with either Sofema Aviation Service www.sassofia.com or Sofema Online www.sofemaonline.com. Users may be considered:

Valued Customer

For the purposes of this policy, Sofema Aviation Services defines the term “valued customer” as a person or entity with which Sofema Aviation Services has an established relationship, consent is continuous and ongoing with a strict unsubscribe remove & delete policy.

Inquirer

The term “Inquirer” as any individual who responds to surveys or contacts Sofema Aviation Service or Sofema Online in response to Sofema Aviation Services marketing material the inquirer agrees as a function of the engagement that we can process their data in so much as is required to respond with them and engage in meeting their needs and objectives

Visitor

The term “Visitor” as an individual that visits our front-end website (for example www.sassofia.com & www.sassofia.com).

Any information stored on Sofema Aviation Services’s platform is treated as confidential. All information is stored securely and is accessed by authorized personnel only. Sofema Aviation Services implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

2.1 What data we do collect


Personal data type

Email Addresses

Source Sofema Aviation Services Collects Data from our websites, customers, direct contacting from our advertising and marketing activities, including LinkedIn and Facebook.

Contact Name

We will use this to service Your enquiry and to ensure we are speaking to the correct person when we make contact.

Contact Number

We will use this to service Your enquiry, we will call You so we can discuss Your enquiry with Yourself.

Contact Email

We will use this to service Your enquiry, we will email details of the product You have enquired about.

Product or/and Services Interested In

We will use this to service Your enquiry, we will use this so the relevant person can deal with Your enquiry ensuring You receive the best level of service.

Time Stamp & Date Stamp of Enquiry

We will use this to service Your order and for compliance to ensure we can provide proof of enquiry made.

IP Address Enquiry Made On

We will use this for compliance to ensure we can provide proof of enquiry made.

2.2 How do we collect data


You directly provide our Company with most of the data we collect. We collect and process data when You:

• Register online and/or place an order for any of our products or services

• Place an order or inquiry for any of our products or services via email, LinkedIn, or any other social platform

• Fill „My Profile” information within the www.sofemaonline.com website by typing in Your information

• Voluntarily complete a customer survey or provide feedback on any of our google forms or via email

• Voluntarily send an inquiry via  and www.sofemaonline.com free forms

• Request to Access Resources in www.sassofia.com Library

• Use or view our web site via browser cookies

2.3 What happens to the Data Collected and How we use it


We will use Your data to find out Your requirements and if You are interested in consultancy & training we will understand Your requirements and provide You with an introduction to the most suited web lead supplier where we may receive a commission for the introduction, where we do not produce web leads ourselves.

We provide open and “in company” EASA compliant regulatory training and for this purpose we retain information provided by You for the duration of the engagement.

During a User’s registration on Sofema Aviation Services’s platform, they provide information such as name, company name, email, address, telephone, credit card number and other relevant data. This information is used by Sofema Aviation Services to identify the User and provide them with support, services, mailings, sales and marketing actions, billing and to meet contractual obligations.

Sofema Aviation Services does not store any digital financial data following website transactions. Sofema Aviation Services will not retain any user data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations.

a) We provide our valued customers with a regular update of our current activities and information concerning the availability of forthcoming training for this purpose we store names and email addresses only without any other personal contact information. We provide proforma invoices and final invoices related to the provision of our services.

b) We provide our Inquires with a response to their question which may include a quotation or a request for further information to understand fully the requirement of the Inquirer.) We provide pro-forma invoices and final invoices related to the provision of our services

If you are a visitor to our websites. We may record your IP address and use cookies. Sofema Aviation Services may add information collected by way of pageview activity. Furthermore, Sofema Aviation Services may collect and process any Personal Data that you volunteer to us in our website’s forms, such as when you register for events or sign up for information and newsletters. If you provide Sofema Aviation Services with your social media details, Sofema Aviation Services may retrieve publicly available information about you from social media.

2.4 How do we store Your data


Your data is being kept on secure thirdparty servers, however, access to Your personal and professional data is limited to You and the Sofema Aviation Services Administrator (for the purposes of system maintenance).

We may also require the service of a third party who have a business need to know such data for the purposes of system development and maintenance. They will only process Your personal data on our instructions, and they are subject to a duty of confidentiality through a non-disclosure agreement following all GDPR requirements.

We have put in place procedures to deal with any suspected personal data breach and will notify You and any applicable regulator of a breach where we are legally required to do so.

Your personal data will be retained to support your ongoing relationship with Sofema Aviation Services unless you express in a written request for this data to be deleted from our servers and to terminate your relationship with Sofema Aviation Services.

2.5 Ensuring our Email and Essential Data Integrity is Maintained


Sofema Aviation Services uses SAS Company email managed by Google Cloud 2.2 & Ensuring Email Integrity is Maintained by using HTTPS encrypted connections whenever users log in to Gmail, no matter the security of the Internet connection they’re on, because the company will be keeping emails encrypted as they move around Google’s servers and from one data center to another.

We have put in place appropriate security measures to prevent Your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

3. What are Your protection rights?


We would like to make sure every User is fully aware of their data protection rights. You are entitled to the following:

• The right to access – You can request a copy of all personal and professional data Sofema Aviation Services collects about You, at any time by contacting us at team@sassofia.com

• The right to rectification – You have the right to request correction of any data You may believe is inaccurate and/or the right to request to complete the information You may believe is incomplete.

• The right to erasure – You have the right to request erasure of a part or all personal and professional data from our database at any time by contacting us on team@sassofia.com Our Terms & Conditions apply.

• The right to restrict or object processing – You have the right to restrict and/or object our Company’s method of processing Your data. Please note however, since Sofema Aviation Services’ core function is data processing, this restriction or objection may render a part or whole paid service inoperative. Our Terms & Conditions apply.

You can modify, update, or delete Your account information at any time by contacting us at team@sassofia.com You may inquire as to whether team@sassofia.com is Processing Personal Information about You and ask that we correct, amend or delete Your Personal Information where it is inaccurate by contacting us at team@sassofia.com.

Please include Your full name and email address and a detailed description of Your data request. Such requests will be processed in line with local laws. We will respond to any requests for access to personal

If You wish to exercise Your rights or have another query related to our Privacy Policy, please contact us on team@sassofia.com

4. Marketing


By registering and accepting our Terms & Conditions and Privacy Policy, You agree to be on our mailing list by default.

You have the right to be removed from the mailing list for marketing purposes at any time, by sending us an email on marketing@sassofia.com.com

5. Website Visitors


If You are a Visitor to our website only, and not for example a valued customer or enquirer to a survey or a user of our platform, then this section is relevant for You.

By visiting www.sassofia.com & www.sofemaonline.com, You consent to the collection and use of Your Personal Data as described herein. If You do not agree with the terms set out herein, please do not visit this website. If required by applicable law, we will seek Your explicit consent to process Personal Data collected on this website or volunteered by You. Kindly note that any consent will be entirely voluntary. However, if You do not grant the requested consent to the processing of Your Personal Data, the use of this website may not be possible.

Sofema Aviation Services may collect, record and analyze information of Visitors to its website. We may record Your IP address and use cookies. Sofema Aviation Services may add information collected by way of pageview activity. Furthermore, Sofema Aviation Services may collect and process any Personal Data that You volunteer to us in our website’s forms, such as when You register for events or sign up for information and newsletters. If You provide Sofema Aviation Services with Your social media details, Sofema Aviation Services may retrieve publicly available information about You from social media.

Such Personal Data may comprise Your IP address, first and last name, Your postal and email address, Your telephone number, Your job title, data for social networks, Your areas of interest, interest in Sofema Aviation Services products, and certain information about the company You are working for (company name and address), as well as information as to the type of relationship that exists between Sofema Aviation Services and Yourself.

Sofema Aviation Services gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come.

6. Our legal basis for processing for the personal Data.


If You decided to enter into a business agreement with Sofema Aviation Services under the contract, we will need to process Your details to service Your order.

The special categories of personal data:

We do not process any special categories. We have included a list of what these categories are for Your records under GDPR.

• Racial

• Ethnic origin

• Political opinions

• Religious beliefs

• Philosophical beliefs

• Trade union membership

• Genetic data

• Biometric data

• Health data

• Data concerning a natural person’s sex life

• Sexual orientation

7. Cookies 7.1. What are Cookies


Browser cookies or tracking cookies, are small, often encrypted text files, located in browser directories. They are used by web developers to help users navigate their websites efficiently and perform certain functions. Due to their core role of enhancing/enabling usability or site processes, disabling cookies may prevent users from using certain websites.

For more information, please visit allaboutcookies.org

7.2. How do we use Cookies?


We use our cookies to:

• Keep You signed in

• Understand how You use our website

• Analyze traffic on our web site

• Provide social media features

We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you have provided to them or that they’ve collected from your use of their services.

7.3 What type of Cookies do we use?


Functionality – Our Company uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

7.4 How to manage Your Cookies?


You can always set your browser not to accept cookies, however in a few cases, some of our website features may not function as a result.

8. Links to other sites


Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our sphere of influence. Sofema Aviation Services is not responsible for the content or privacy policy of these other sites.

9. Website Visitor Response


Visitors to Sofema Aviation Service and Sofema Online Website should be aware that in responding to surveys or survey invitations, they could be disclosing information that could make them personally identifiable to Sofema Aviation Services.

Sofema Aviation Services will not process Personal Data of Respondents for other purposes or by other means than instructed by its Users.

9.1. Users 9.1.1. General


In order to provide services to its Users, Sofema Aviation Services collects certain types of data from them.

9.1.2. Collection of User Data


Sofema Aviation Service and Sofema Online Surveys are used for gathering feedback and to understand opportunities for service improvement.

Sofema Aviation Services will not process Personal Data for other purposes or by other means than instructed by its Users.

The purpose of collecting Personal Data as part of a survey will vary depending on the survey, as set up by Sofema Aviation Services’ Users.

Sofema Aviation Services may provide from time-to-time surveys For Users in the EEA, or for Users providing surveys to Respondents in the EEA, Sofema Aviation Services will be the “controller”, as defined in the Directive and the GDPR.

Sofema Aviation Services will not retain User data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations.

9.1.3. Collection of Respondent Data


Surveys used for gathering feedback are created by Users, who make them available to relevant businesses, organizations, and individuals. It is the User’s responsibility to ensure that collection and processing of data is done in accordance with applicable law. Sofema Aviation Services will not process Personal Data for other purposes or by other means than instructed by its Users.

Respondent data includes data from individuals uploaded, transferred or manually entered by a Sofema Aviation Services User into their account for the purpose of providing feedback to the User by responding to surveys. Personal Data may include, personal contact information such as name, home address, home telephone or mobile number, email address, information concerning family, lifestyle and social circumstances including age, date of birth, marital status, number of children, employment details, education/qualification, business contact details, gender, religion, race, health detail and other sensitive Personal Data. Answers to questions by Respondents, may also include Personal Data.

The purpose of collecting Personal Data as part of a survey will vary depending on the survey, as set up by Sofema Aviation Services’s Users. As Sofema Aviation Services provides surveys to a wide group of customers and businesses, the purpose may vary greatly. For Users in the EEA, or for Users providing surveys to Respondents in the EEA, the User will be the “controller”, as defined in the Directive and the GDPR. The purpose will consequently be defined by Sofema Aviation Services’s User.

All data collected by Sofema Aviation Services Users through surveys will be stored exclusively in secure hosting facilities provided by Dropbox.

If You or Your organization are required under the European Union’s General Data Protection Regulation (GDPR) to enter into a contract, or other binding legal act under EU or Member State law, with Your data processors, review and accept Sofema Aviation Services’s Data Processing Agreement in Your Sofema Aviation Services account.

10. Processing in the European Economic Area (EEA)

For Users with accounts located in Sofema Aviation Services’s European Data Region, all processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Sofema Aviation Services’s processing will take place in accordance with the GDPR.

All processing is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

11. Acceptance of these Conditions


We assume that all Visitors of our website, Respondents to surveys powered by Sofema Aviation Services and users Sofema Aviation Services’ platform have carefully read this document and agree to its contents.

If someone does not agree with this privacy policy, they should refrain from using our website and platform. We reserve the right to change our privacy policy as necessity dictates. Continued use of Sofema Aviation Services website and platform after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy.

This privacy policy is an integral part of Sofema Aviation Services’ Terms and Conditions.

12. Our Legal Obligation to Disclose Personal Information


We do not normally share Your personal data with third parties, however should this be necessary in the future for valid business reasons we will only pass Your personal data on to third-party service if You provide us with explicit consent.

Any third parties that we may share Your data with are obliged to keep Your details securely, and to use them only to fulfil the service they provide to You we will have no affiliation to the service they provide but may receive a commission for the introduction.

When they no longer need Your data to fulfil this service, they will dispose of the details in line with Sofema Aviation Services procedures.

If we wish to pass Your sensitive personal data onto a third party we will only do so once we have obtained Your consent, unless we are legally required to do otherwise.

We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Sofema Aviation Services or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.

No Data is processed without a valid reason and we do not share Data with any 3rd Parties for any reason whatsoever.

All information is stored securely and is accessed by authorized personnel only.

Sofema Aviation Services implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

We regularly review and update our policies and provide our employees with security training; we perform process audits and conduct risk assessments; and monitor compliance with security policies.

We operate a strict unsubscribe policy so at any time You wish to be removed or excluded from any or all communications we will do so and remove all information from our database.

Exceptionally, through special circumstances, upon a special request and where legally bound, we may share Your personal and professional details with third parties.

Likewise, a court order may require Sofema Aviation Services to communicate personal data to people authorized by the order to inspect the personal data concerned.

Please note, we make an exception to our non-disclosure undertaking in the event of a partial or complete reorganization or a transfer of the Company’s business operations.

In such cases, your personal data will be conveyed along with the business operations to the third parties involved in the transfer and in the confidential negotiations prior to the transfer.

As far as possible, Sofema Aviation Services will inform you of the transfer to the third parties.

13. Sofema Aviation Services' Data Protection Officer


Sofema Aviation Services has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection.

Sofema Aviation Services has appointed Petya Zhelyazkova (General Manager Online Services) as Data Protection Officer for both Sofema Aviation Services and Sofema Online.

Petya Zhelyazkova is responsible for the oversight of the implementation of the Data Protection Program – You may contact her at the following email petya.zhelyazkova@sassofia.com

This Data Protection Officer can be reached at the following address:

Sofema Aviation Services

Attn: Data Protection Officer, 19 Yakubitsa Str, fl. 4, Bulgaria

Petya.zhelyazkova@sassofia.com

14. Changes to our Privacy Policy


Our Company keeps its privacy policy under regular review and places any updates on this web page. Any substantial change to this Privacy Policy will be communicated with Users, prior to the update.

This privacy policy was last updated on 27th March 2023.

15. For Further Information


If You have any further questions regarding the data Sofema Aviation Services collects, or how we use it, then please feel free to contact us by mail.

Sofema Aviation Services

Attn: Data Protection Officer, 19 Yakubitsa Str, fl. 4, Sofia, Bulgaria, email: team@sassofia.com