General Data Protection Regulation – Regulation (EU) 2016/679, of 27 April, considers personal data to be “information relating to an identified or identifiable natural person (‘data subject’)”.
A natural person is regarded as identifiable if he/she can be identified, directly or indirectly, especially by reference to an identifier such as a name, an identification number, location data, online identifiers or one or more factors specific to that person’s physical, physiological, genetic, mental, economic, cultural or social identity.
Absant Group acknowledges that the use of your personal data should be carried out consciously, fostering a relationship of trust and respect for YOUR privacy.
The purpose of this document is to inform you of the rules governing the processing of your personal data, the rights to which you are entitled, and to explain how you can manage them.
Through this Personal Data Privacy Policy, Absant Group intends to:
- Inform its clients about the purposes underlying the collection, use/processing, and disclosure of their personal data while using its Training Services;
- Request YOUR informed consent to collect and process YOUR personal data. Consent is given by the Data Subject by accepting the terms set out in this document.
Training Services:
In compliance with Article 7 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data, Absant II Training, Lda. requests your consent (as Data Subject) so that, within the scope of providing Training Services, and solely for that purpose, it may process such data to fulfil its duties as a Training Entity certified by the Directorate-General for Employment and Labour Relations (DGERT) in Portugal and the National Civil Aviation Authority (ANAC) also from Portugal, namely all matters relating to the technical/administrative management of the Training Activities (in classroom or distance learning) you attend, including issuing Training Services Contracts and Training Certificates.
Your consent is required to enter into a Training Service Contract, meaning you cannot participate in Training Activities with Absant II Training, Lda. without providing the requested personal data.
What personal data does Absant II Training, Lda. requests from you for providing Training Services?
For compliance with its duties as a DGERT and ANAC certified Training Entity, Absant II Training, Lda. may request some or all of the following personal data from trainees:
- Full name;
- Date of birth;
- Identification document number and validity;
- Place of birth and nationality;
- Educational qualifications (if applicable);
- Address;
- VAT Number;
- Email;
- Position/Job function;
- Mobile phone number.
How is your personal data collected?
Personal data is collected by Absant II Training, Lda. through the following channels:
- Institutional website (absant-group.pt), specifically the “Client Area”, a restricted-access area used solely by the Customer Support Services of Absant II Training, Lda.;
- Email (formacao@absant-group.pt or formacao.uas@absant-group.pt), managed by Absant II Training, Lda Customer Support Services;
- In person, by filling out a Training Registration Form, processed by Absant II Training, Lda Customer Support Services;
- For e‑Learning and b‑Learning training, data is collected via any of the channels above and made available on the proprietary online Training Platform (https://moodle.absant-group.pt/), a restricted‐access area used only by Customer Support Services;
Personal data will be retained for the applicable periods in accordance with the duties of DGERT certified Training Entities in Portugal and the technical and regulatory requirements of ANAC Portugal or applicable European or international regulation regarding civil aviation training activities.
Data will also be used for the following additional purposes:
- By Customer Support Services to respond to any Client´s questions and to provide clarification (whether technical, commercial, or complaints) and to share annual Training Programmes and schedules;
- Pedagogical quality control: at the end of Training Activities you attend, feedback will be requested, which can be given anonymously and will be used exclusively for quality control and continuous improvement, as required to DGERT Certified Entities;
- Portability and disclosure to third parties:
- For mandatory registration on the SIGO Platform (Integrated Information and Management System for Educational and Training Offer – only for Portuguese Trainees);
- For transmission to the DGERT Accreditation System for possible monitoring procedures – only for Portuguese Trainees);
- For ANAC Portugal, for issuance of certificates (when applicable;
- Corporate communications and service promotion:
- Testimonials may be requested at the end of Training Activities, optionally and anonymously, and may be published on social media and Absant II Training, Lda institutional website;
- Group photographs of the training class may also be taken, optionally, and with previous consent by all involved, and may be shared on social media and the company website.
Data will not be used for any other purposes beyond those identified, specifically no automated decision-making about the Data Subject, no profiling of clients for commercial purposes, nor any sale or other business with third parties.
Data will only be shared with the entities identified here, except when legally required otherwise.
Rights of Data Subjects:
Please be informed that you have the following rights:
- Request access to your personal data, and respective correction, or restriction of processing, but be aware that exercising these may limit your ability to participate in training or receive certificates, even if training is concluded successfully.
- Object to processing and data portability, with the same limitations regarding training participation and certification, even if training is concluded successfully.;
- Request deletion of your personal data (“right to be forgotten”), but consider possible limitations that will prevent data recovery and certification;
- File a complaint with the Supervisory Authority — the Portuguese Data Protection Authority (CNPD), Rua de São Bento, 148, 3º, 1200-812 Lisbon; Tel. +351 213 928 400; Fax +351 213 976 832; Email: geral@cnpd.pt;
- At any time, you may request inspection, modification, or cancellation of your personal data in accordance with the purposes described herein.
For corporate clients:
Training Services:
Corporate clients using training services confirm that they:
- Are aware of and agree to Absant II Training, Lda.’s Privacy Policy;
- Have informed their employees of the purposes for which they provide their personal data to Absant II Training, Lda;
- Have obtained informed consent from their employees and can produce evidence to Absant II Training, Lda, when requested.
Absant II Training, Lda. emphasises that corporate client employee data provided for training services will be used exclusively in compliance with this Privacy Policy, in full respect of Regulation (EU) 2016/679.
Consultancy Services (Absant Consult, Lda.):
Corporate clients confirm they:
- Know and agree to Absant Consult, Lda.’s Privacy Policy;
- Have informed their employees about using their data;
- Have obtained from their employees and can produce evidence to Absant Consult, Lda, when requested.
What personal data may Absant Consult, Lda. have access?
For consultancy service provision, Absant Consult, Lda. may receive the following data:
- Name (full or partial);
- Date of birth;
- Identification document number and validity;
- Place of birth and nationality;
- Educational qualifications (if applicable);
- Address;
- NIF;
- Email;
- Job function;
- Digital signature (scanned);
- Work mobile phone number;
- Training Records.
Purpose of use:
This data is used solely for consultation and completion of proprietary documentation for clients (e.g. operations manuals and forms, audit reports, operational exercise reports), and will not be shared with third parties except ANAC Portugal and other NAAs, when legally required.
Data will not be used for other purposes, such as automated decisions, profiling, sale, or other third-party business.
Rights of Data Subjects:
The same rights as indicated above apply.
For both Training and Consultancy Services:
How is your personal data secured?
Absant Group, through Absant II Training, Lda. and Absant Consult, Lda., undertakes to protect supplied personal data by implementing mandatory technical and procedural measures for all personnel involved, including:
- Use of proprietary information systems with protection via firewalls, restricted access policies, intrusion detection and real‑time monitoring.
- Encrypted storage;
- Internal and external backups to ensure data protection and business continuity.
How to access, modify or withdraw consent?
To access, update or delete your personal data, you may use the channels identified above, using your private user credentials, or contact Absant Group’s Customer Support, stating your request and reason. The process will be handled by the Data Protection Officer of ABSANT GROUP.
Likewise, you may withdraw your consent at any time by contacting the Data Protection Officer in person at company facilities or by other means, always providing proof of identity.
Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.