Virtual Aurigny – Privacy Policy
Virtual Aurigny (“we”, “us”, “our”) is committed to protecting the privacy and security of personal data. We process personal information in accordance with the Data Protection Act 1998, its subordinate legislation, and the General Data Protection Regulation (GDPR), effective from 25 May 2018. This Privacy Policy sets out the basis on which personal data is collected, processed, stored, and disclosed by Virtual Aurigny.
1. Scope of this Policy
1.1
This Privacy Policy applies exclusively to:
• The vAMSYS platform as used by Virtual Aurigny; and
• The Virtual Aurigny – Sarnia Operations Hub website.
1.2
This Policy does not apply to external websites that may be linked from our services. Third‑party websites operate under their own privacy policies, and Virtual Aurigny accepts no responsibility for their data handling practices.
2. Data Collection
2.1
We may collect personal data when you:
• Submit an application to join Virtual Aurigny;
• Register or log in to the Virtual Aurigny website;
• Respond to requests for personal information.
2.2
This information is collected to support operational, administrative, and community‑management functions and to improve our services.
3. Data Security and Compliance
3.1
All personal data provided to Virtual Aurigny is stored securely and processed in accordance with applicable data protection legislation.
3.2
We implement appropriate technical and organisational measures to prevent unauthorised access, disclosure, alteration, or loss of personal data.
4. Fair Processing and Transparency
4.1
When personal data is supplied to us, we fulfil our legal obligations by:
• Collecting data fairly and lawfully;
• Informing individuals of the purposes for which their data will be used.
4.2
We are committed to maintaining transparency in all aspects of data processing.
5. Third‑Party Disclosure
5.1
We do not share personal data with third parties except:
• Where required by law;
• Where necessary for the operation, security, or maintenance of our services;
• Where required to verify identity or eligibility with vAMSYS.
5.2
We do not sell personal data under any circumstances.
6. Policy Updates
6.1
This Privacy Policy may be amended periodically.
6.2
Material changes will be announced prominently on the Virtual Aurigny Discord under the heading “Changes to the Privacy Policy.”
7. Security Reminder
Users are strongly advised to employ unique passwords for each online service. Reusing passwords increases the risk of unauthorised access.
8. Data Controller
8.1
For personal data processed directly by the Virtual Aurigny – Sarnia Operations Hub website (including internal vacancy applications), Virtual Aurigny acts as the Data Controller.
Contact for privacy matters:
Email: ceo@virtualaur.co.uk
9. vAMSYS as System of Record
9.1
Virtual Aurigny uses vAMSYS to manage operational pilot records, including flight data and statistics.
9.2
Depending on its service model and contractual terms, vAMSYS may act as a separate data controller or data processor.
9.3
Virtual Aurigny does not intentionally duplicate full operational pilot records on this website.
10. Personal Data Collected on This Website
10.1
We adhere to the principle of data minimisation.
10.2
Data collected may include:
• Name
• Virtual Aurigny Pilot ID
• vAMSYS ID
• Discord ID
10.3
We do not collect or store email addresses for vacancy applications.
11. Lawful Bases for Processing
11.1
Under the UK GDPR, we rely on the following lawful bases:
11.1.1 Legitimate Interests (Article 6(1)(f))
Used for:
• Administration of internal roles and vacancy applications;
• Verification of identity against vAMSYS records;
• Ensuring the integrity and security of the Virtual Aurigny community.
11.1.2 Consent (Article 6(1)(a))
Used only where explicitly requested (e.g., optional features).
Consent may be withdrawn at any time where applicable.
12. Sharing of Personal Data
12.1
Personal data may be shared only where necessary:
• With vAMSYS for identity verification or eligibility checks;
• With service providers responsible for hosting or securing the website (acting under our instructions);
• Where required by law or to protect our legal rights.
12.2
We do not sell personal data.
13. International Transfers
13.1
Where service providers process data outside the United Kingdom, we ensure that appropriate safeguards—such as Standard Contractual Clauses—are in place in accordance with legal requirements.
14. Data Retention
14.1
Personal data is retained only for as long as necessary for the purposes for which it was collected.
14.2
Records relating to internal vacancy applications may be deleted once decisions and associated administrative processes are complete.
15. Your Rights
15.1
Subject to applicable law, individuals may have the right to:
• Access personal data;
• Request rectification of inaccurate or incomplete data;
• Request erasure (“right to be forgotten”);
• Request restriction of processing;
• Object to processing based on legitimate interests;
• Request data portability (where applicable).
15.2
Requests relating to data processed by the Virtual Aurigny – Flight Operations Center website should be directed to the contact listed in Section 8.
15.3
Requests relating to operational pilot data held within vAMSYS may need to be directed to vAMSYS directly.
16. Security
16.1
We implement appropriate technical and organisational measures to safeguard personal data.
16.2
However, no system can be guaranteed to be entirely secure.
17. Cookies
17.1
Our website may use essential cookies or similar technologies to ensure correct functionality, including security and session management.
17.2
Where optional cookies are used, consent will be requested where legally required.
18. Complaints
18.1
Individuals with concerns regarding the processing of their personal data are encouraged to contact us in the first instance.
18.2
Individuals may also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO).
19. Changes to This Policy
19.1
We may update this Privacy Policy from time to time.
19.2
The most recent version will always be available on this website.
19.3
Continued use of the website following any updates constitutes acceptance of the revised Policy.