Privacy Policy
California residents, please see our new California Privacy Notice here
TSAL is a company registered under the laws of India, having registered office at Jeevan Bharti Tower 1, 10th Floor, 124 Connaught Circus, New Delhi- 110001, India, and corporate office at Intellion Edge, Tower A, 9th & 10th Floor, South Peripheral Road, Sector – 72, Gurgaon, Haryana-122101, India. TSAL is engaged in the business of operating, managing, and providing scheduled air transport services under the brand name ‘Vistara’. For the purpose of the European Union General Data Protection Regulation or the United Kingdom General Data Protection Regulation read together with the Data Protection Act 2018 (as amended), (collectively referred as “GDPR”), TSAL is the ‘data controller’, for the purpose of the Singapore Personal Data Protection Act, 2012 ("Singapore PDP Act"), TSAL is the 'organisation'. TSAL’s data protection officer can be contacted at dpo@airvistara.com.
TSAL collects, uses, and discloses Visitors/Users Data (as defined below) for a number of purposes, including, but not limited to various trainings as per the DGCA and EASA Regulations. The collection, use and disclosure of Visitors/Users Data enables TSAL to conduct training and issue certificate of completion of training. This Privacy Policy is applicable to all the Visitors/Users s who visit our App or website to get the information and enrol for various available trainings. This Privacy Policy outlines TSAL’s policy and responsibility in relation to the collection, use and disclosure of Visitors/Users Data.
By continuing to use our website (https://vlearn.airvistara.com/) including the related link/pages (“Website”), you signify that you have read, understood, and agree to this Privacy Policy.
SUMMARY
What information do we collect about you?
We collect information when you visit, use or access our App or Website, such as your Name, Date of Birth, Place of Birth, Contact details, Government Photo ID (applicable for certain trainings only). In addition to this, we collect device and technical information from you when you use the Website. For more information, please refer Section 1 “The types of Visitors/Users Data we collect”.
How will we use the information about you?
We use your information for a number of purposes, including not limited to, comply with various regulations issued by DGCA and EASA from time to time. For more information, please refer Section 3 “How we use your Visitors/Users Data”.
Who do we share your information with?
We share your data with our internal stakeholders and third-party service providers to the extent necessary to provide their services such as printing and issue of certificates and audit purposes only. We use these third parties’ services solely to process or store your information for the purposes described in this Privacy Policy. We also share your information with government bodies as required by law. For more information, please refer Section 4 “Disclosure of your Visitors/Users Data”.
Where do we process your information?
Our information infrastructure is cloud-based and outsourced. For more information, please refer Section 5 “Transfer of information overseas”.
How long do we keep hold of your information?
TSAL will retain Visitors/Users Data for as long as it is necessary to fulfil the purpose for which it was collected, and for satisfying any legal, business or reporting requirements or as required by relevant laws. For EU and UK residents, we will endeavour to delete data within 30 days of a request for erasure or contact you if it will take longer. For more information, please refer Section 8 “Retention”.
However, as per DGCA and EASA Regulations, the details and data of the training have to maintained for unlimited period for audit purposes.
How can I exercise my rights over my information?
You have various rights in relation to your data.
For more Information for non-EU and UK residents, please refer Section 6 “Non-EU and UK Data Subject Rights”.
For more Information for EU and UK residents, please refer Section 7 “EU and UK Data Subject Rights”.
Dispute Resolution
If you have any concerns or complaints, please contact us at the addresses mentioned in Section 14 “Contact us”.
How will we notify you of changes?
TSAL will amend this Privacy Policy from time to time and the updated versions will be posted on the Application and Website. Please check back frequently to see any updates or changes to this Privacy Policy.
For more information, please refer Section 13 “Updates to the privacy policy”.
The types of Visitors/Users Data that TSAL collects, depends on the circumstances of collection and on the nature of job/role.
- Personal Data.
Name
Date of Birth
Place of Birth
Period of Training
Sponsoring Organization (If applicable)
Address for communication
Contact Number
Email Id
Government issued Photo ID
- Technical Data. This may include device and technical information you give us when using the Application or Website such Name of the training, duration of the training, training attendance as applicable, Examination results (as applicable). While accessing the Website, you may be redirected to third party platforms and their cookie policy would be applicable which may be required for the recruitment process.
For purposes of this Privacy Policy, Visitors/Users Data means Personal Data and Technical Data.
We also use Visitors/Users Data to derive statistical data. This is processed and stored purely for analytical purposes and is entirely anonymous. This information will not be stored to your record and will only be aggregated for statistical analysis so that we can better understand job profile and improve the Website.
Special categories of information or “sensitive personal data”Certain categories of Visitors/Users Data, such as information about your race, ethnicity, religion or health, are considered special categories of information, or “sensitive personal data” under the GDPR. Similarly, medical and financial data such as bank account details, payment details, and personal identifiers such as passport details are treated as sensitive for the purpose of the Singapore PDP Act.
Generally, we try to limit the circumstances where we collect your sensitive personal data. However, this may be required in case of type trainings only.
How we collect data from you
TSAL collects Visitors/Users Data, either directly from you or from the following sources:
- eLearning portal profile update
The collection of the Visitors/Users Data (as required for particular training) is mandatory to enable TSAL to comply with the DGCA and EASA Regulations. If you do not provide this information, we will not be able to evaluate your application
If you are an EU / UK / Singapore resident, we are required to disclose the legal basis for processing your data under the GDPR / Singapore PDP Act. We will use the Visitors/Users Data in the following purposes:
- For training purposes as mandated by DGCA and/or EASA
- Compliance – Maintaining mandatory and legal requirements and for corporate governance.
You have the right to withdraw your consent at any time by contacting us at dpo@airvistara.com.
TSAL will share your Visitors/Users Data with third party service providers to the extent necessary to provide their services such as printing and issue of certificates and audit purpose.
TSAL may disclose the Visitors/Users Data to law enforcement agencies, public, regulatory authorities, if legally required to do so, or if we have a good faith belief that such use is necessary to:
comply with legal obligation, process, or request.
enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent, or otherwise address security, fraud, or technical issues; or
protect the rights, property, health or safety of us, our users, a third party or the public as required or permitted by law (including exchanging Visitors/Users Data with other companies and organisations for the purposes of fraud protection and credit risk reduction).
We will also disclose your Visitors/Users Data to third parties:
if we sell or buy any business or assets, in which case we may disclose your data to the prospective seller or buyer of such business or assets.
if we or substantially all our assets are acquired by a third party, in which case Visitors/Users Data held by us about will be one of the transferred assets; or
to comply with legal obligations, processes, or requests (such as disclosing Visitors/Users Data to executors in response to court orders).
In addition, TSAL may disclose Visitors/Users Data to our legal advisors for establishing, exercising, or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law. TSAL also reserves the right to share Visitors/Users Data as is necessary to prevent a threat to the life, health, or national security of an individual or corporate entities such as TSAL. Further, TSAL will disclose Visitors/Users Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
TSAL’s Corporate Office is based in Gurgaon, Haryana, India. TSAL’s infrastructure is primarily based on Cloud and its Core Systems are Software as Service (SaaS) in nature where its Visitors/Users Data is stored and accessed. Visitors/Users Data will be accessible to TSAL’s offices, agents and service providers in India and around the world in connection with Trainings and Audit of training by Internal Auditors, Auditors from DGCA and/or EASA.
This means that Visitors/Users Data may be transferred to, and stored at, a destination outside of your country and outside the European Economic Area ("EEA"), Singapore and UK.
We will ensure the same standard of protection as required under your country of residence will provided to your Visitors/Users Data and undertake any other measures required under applicable law to affect such transfer.
If you are not a resident in the EU or UK, you may have certain rights in relation to the Visitors/Users Data we hold about you, which are detailed below.
Access.You have the right to know whether we are in possession or are processing Visitors/Users Data about you, and if we do, to access Visitors/Users Data we hold about you and certain information about how we use it and who we share it with.
TSAL reserves the right to deny you access to your Visitors/Users Data if the burden or expense of providing access would be unreasonable to TSAL or disproportionate to your interest, or if the request is frivolous or vexatious and may provide an explanation as required by applicable laws.
Correction.You have the right to seek corrections of any Visitors/Users Data held about you that is inaccurate or incomplete.
Option to withdraw consent.You may, at any time, withdraw any consent given or deemed to have been given under the Singapore PDP Act in respect of the collection, use, or disclosure of their Visitors/Users Data for any purpose by TSAL.
Feedback and complaintsIf you have any concerns, feedback, or complaints about the use and/or sharing of your Visitors/Users Data, we are open to receiving your feedback or complaints
Exercise of Rights.To exercise any of your rights, please contact us at dpo@airvistara.com. We will respond to your access request as soon as possible. If we are unable to respond to your access request within 30 days, we will inform you by when we can provide the response.
If you are a resident in the EU or UK, you may have certain rights in relation to the Visitors/Users Data we hold about you, which are detailed below. Some of these only apply in certain circumstances where TSAL is holding authority of the data and legally/contractually allowed as per the local laws as set out in more detail below. We also set out how to exercise those rights.
These rights include:
The right of access.
The right of data portability.
The right of rectification.
The right of erasure.
The right to restrict processing.
The right to object.
Please note that we will require you to provide us with proof of identity and address before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo@airvistara.com.
Complaints.
If you wish to make a complaint about how we process your Visitors/Users Data, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.
If you are a UK resident and are dissatisfied with the way we have handled your complaint or request and want to make a complaint, you may write to the Information Commissioner, who is an independent regulator. Any complaint to the Information Commissioner is without prejudice to your right to seek redress through the courts.
The Information Commissioner can be contacted at:
Information Commissioner's Office, Wycliffe House Water Lane Wilmslow Cheshire, SK9 5AF, Email: icocasework@ico.org.uk; Tel: 0303 123 1113; Textphone: 01625 545860; Website: https://ico.org.uk.
Access.
You have the right to know whether we process Visitors/Users Data about you, and if we do, to access Visitors/Users Data we hold about you and certain information about how we use it and who we share it with.
We may not provide you with certain Visitors/Users Data if providing it would interfere with another’s rights (e.g., where providing the Visitors/Users Data we hold about you would reveal information about another person) or where another exemption applies. We may refuse any request or deny you access to your Customer Data if the request is excessive or unfounded and will provide you the explanations in writing as required by applicable laws.
Portability.
You have the right to receive a subset of the Visitors/Users Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Visitors/Users Data to another party.
The relevant subset of Visitors/Users Data is data that you provide us with your consent or for the purposes of performing our contract with you.
If you wish for us to transfer the Visitors/Users Data to another party, please ensure you detail that party and note that we can only do so where it is legally, contractually and technically feasible. We are not responsible for the security of the Visitors/Users Data, its transmission or it’s processing once received by the third party. We also may not provide you with certain Visitors/Users Data if providing it would interfere with another’s rights (e.g., where providing the Visitors/Users Data we hold about you would reveal information about another person).
Correction.
You have the right to correct any Visitors/Users Data held about you that is inaccurate. Please note that whilst we assess whether the Visitors/Users Data, we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
Exercise of Rights.
To exercise any of your rights, please contact us at dpo@airvistara.com .
Erasure.
You may request that we erase the Visitors/Users Data we hold about you in the following circumstances:
- you believe that it is no longer necessary for us to hold the Visitors/Users Data we hold about you.
- we are processing the Visitors/Users Data we hold about you based on your consent, and you wish to withdraw your consent and there is no other ground under which we can process the Visitors/Users Data.
- we are processing the Visitors/Users Data we hold about you based on our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Visitors/Users Data.
or
- you believe the Visitors/Users Data we hold about you is being unlawfully processed by us.
Also note that you may exercise your right to restrict our processing of the Visitors/Users Data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Visitors/Users Data, if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) or as per TSAL policy in this regard but we will let you know if that is the case. Please note that after deleting the Visitors/Users Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
Where you have requested that we erase Visitors/Users Data that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Visitors/Users Data or providing links to the Visitors/Users Data to erase the Visitors/Users Data too.
To exercise any of your rights, please contact us at dpo@airvistara.com.
Restriction of Processing to Storage Only.
You have a right to require us to stop processing the Visitors/Users Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Visitors/Users Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g., for the defence of legal claims or for another’s protection).
You may request we stop processing and just store the Visitors/Users Data we hold about you where:
- you believe the Visitors/Users Data is not accurate, for the period it takes for us to verify whether the Visitors/Users Data is accurate;
- we wish to erase the Visitors/Users Data as the processing we are doing is unlawful, but you want us to just store it instead;
- we wish to erase the Visitors/Users Data as it is no longer necessary for our purposes, but you require it to be stored for the establishment, exercise or defence of legal claims; or
- you have objected to us processing Visitors/Users Data we hold about you based on our legitimate interest, and you wish us to stop processing the Visitors/Users Data whilst we determine whether there is an overriding interest in us retaining such Visitors/Users Data.
Objection
You have the right to object to our processing of Visitors/Users Data about you and we will consider your request in other circumstances as detailed below by contacting dpo@airvistara.com referencing: Data Subject Rights.
You may object where we are processing the Visitors/Users Data we hold about you (including where the processing is profiling) based on our legitimate interest and you object to such processing.
Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the Visitors/Users Data whilst we make the assessment on an overriding interest. Please refer para with the heading “Restriction of Processing to Storage Only” under Section 7.
We reserve the right to charge a reasonable administrative fee for dealing with your request.
TSAL will retain Visitors/Users Data for as long as it is necessary to fulfil the purpose for which it was collected, and for satisfying any legal, business, or reporting requirements or as required by applicable laws. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
TSAL needs your assistance to ensure that your Visitors/Users Data is current, complete and accurate. As such, please inform TSAL of changes to your Visitors/Users Data by contacting TSAL and submitting your updated particulars to TSAL in writing (see Section 14). TSAL reserves the right to charge a reasonable administrative fee for this service.
TSAL takes reasonable security arrangements to ensure the protection of your Visitors/Users Data in its possession or within its control to prevent any unauthorised access, collection, use, disclosure, copying, modification or disposal, or similar risks; and the loss of any storage medium or device on which such Visitors/Users Data is stored. Please note that however, Visitors/Users the transmission of information via the internet is not completely secure. Although we will do our best to protect your Visitors/Users Data, we cannot guarantee the security of your Visitors/Users Data transmitted through any channel, such as the Website; any transmission is at your own risk.
The Website is not directed at children under the age of 18 and TSAL cannot distinguish the age of persons who access and use the Website. If a minor (according to applicable laws) has provided TSAL with Visitors/Users Data, the parent or guardian of the minor should contact TSAL (see Section 14) to remove the relevant Visitors/Users Data and unsubscribe the minor. If we become aware that Visitors/Users Data has been collected from a person under the age of 18 without parental or guardian consent, we will delete this Visitors/Users Data and, where that minor has an account, terminate the minor’s account.
TSAL will amend this Privacy Policy from time to time, and the updated versions will be posted on the Website. Please check back frequently to see any updates or changes to this Privacy Policy. Subject to applicable laws, the English version of this Privacy Policy will prevail over any version of this Privacy Policy in another language.
If you have comments, questions, or complaints about or requests relating to this Privacy Policy, please contact TSAL in writing at the address below referencing ‘Privacy Policy':
DPOTATA SIA Airlines Limited
Intellion Edge, Tower A,
9th Floor, South Peripheral Road,
Sector – 72, Gurugram,
Haryana-122101, India
E-mail: dpo@airvistara.com referencing: [Vistara E-Learning Privacy Policy].