Kratis Training and Consulting understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our associates and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

This Privacy Policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.


What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.


What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:

  1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 10.
  2. The right to access the personal data we hold about you. Part 9 will tell you how.
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 10 to find out more.
  4. The right to be forgotten, subject to the limitations set-out in Part 6, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 10 to find out more.
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us using your personal data for a particular purpose.
  7. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  8. Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 10.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.


What Personal Data Do We Collect?

We collect and process different types of personal data which we receive from our associates (potential and current) in person or via their representative, in the context of our business relationship.

We may also collect and process personal data which we lawfully obtain not only from you but from other entities or other third parties e.g. companies that introduce you to us, or entities that provide information for regulatory compliance (due diligence).

We may also collect and process personal data from publicly available sources (e.g. the Department of Registrar of Companies and Official Receiver, commercial registers, the internet) which we lawfully obtain and we are permitted to process.

If you are a prospective associate or an authorized representative, the relevant personal data which we collect may include: Name, address, contact detail (telephone, fax, email), identification data and authentication data (e.g. signature).


Your obligation to provide us with your personal data

In order that we may be in a position to proceed with a business relationship with you and provide you with services, you must provide your personal data to us which are necessary for the required commencement and execution of a business relationship and the performance of our contractual obligations.


How Do You Use My Personal Data?

Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

For the performance of a contract

We process personal data in order to provide training or consulting services and to issue the respective certification. The purpose of processing personal data depends on the requirements for each service or product and the contract terms and conditions provide more details of the relevant purposes.

For compliance with a legal obligation

There are a number of legal obligations emanating from the relevant laws to which we are subject as well as statutory requirements, e.g. EASA regulations. There are also various supervisory authorities whose laws, directives and regulations we are subject to e.g. the department of Civil Aviation. Such obligations and requirements impose on us necessary personal data processing activities for identity verification in compliance with respective regulations.

For the purposes of safeguarding or servicing legitimate interests

We process personal data so as to safeguard the legitimate interests pursued by us or by a third party. A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. Examples of such processing activities include:

For other reasons, provided you have given your consent

Provided that you have given us your specific consent for processing (other than for the reasons set out hereinabove) then the lawfulness of such processing is based on that consent. You have the right to revoke consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected. This may cover the provision of promotional material for services.


How Long Will You Keep My Personal Data?

We will only retain your personal data for as long as it is necessary for the stated purpose, taking into account also our need to answer queries or resolve problems, provide improved and new services, and comply with legal requirements under applicable laws. This means that we may retain your personal data for a reasonable period after your last interaction with us. In each case, the length of time that we keep the information may be different, but we will only keep the information for as long as we need it.


How and Where Do You Store My Personal Data?

We store your personal data in our database in an electronic form and only approved Kratis’ personnel has access to it.


Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, with the Cyprus Department of Civil Aviation for training verification purposes

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 6.


How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in Part 10. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request.


How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please email your request to the fund’s administrator at: [email protected].