Privacy Policy

Commitment To Privacy

Smart Management Systems Pty Ltd (ACN 631 673 820), its subsidiaries and affiliates in Australia (collectively referred to as Smart Management Systems) are committed to managing personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

In this Privacy Policy, "we" and "us" refers to Smart Management Systems and "you" refers to any individual about whom we collect personal information.

About Smart Management Systems

Smart Management Systems is a global organisation based in Australia which provides flight school management software, Smart Flight Operations Manager (‘Smart FOM’) to flight school providers. Smart FOM is a web service access via any web enabled device.

Smart Management Systems offers a complete range of services, including staff and student profiles, trainings records, aircraft records, scheduling, qualification and accounts management.

Please contact us for a full list of the companies which comprise Smart Management Systems and which are subject to this Privacy Policy.

What information does Smart Management Systems collect about you?

Smart Management Systems products, including Smart FOM, are web-based, so we may require the use of first and last names, billing contact information, a password, and a valid email address as a login. The type of information collected from you may depend on your interactions with us.

Clients and prospective clients

When you enquire about our services or when you become a client of Smart Management Systems, a record is made which includes your personal information.

The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:

• your name, e-mail, postal address and other contact details;
• information about your employer or an organisation who you represent;
• your professional details; and
• any additional personal information you provide to us, or authorise us to collect, as part of your interaction with Smart Management Systems

Prospective employees/applicants

We collect personal information when recruiting personnel, such as your name, contact details, qualifications, and work history. Generally, we will collect this information directly from you.

We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which involve working with children).

Other individuals

Smart Management Systems may collect personal information about other individuals who are not clients of Smart Management Systems. This includes customers and members of the public who participate in events we are involved with; individual service providers and contractors to Smart Management Systems; and other individuals who interact with Smart Management Systems on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with Smart Management Systems. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.

If you are participating in an event we are managing or delivering, we may take images or audio- visual recordings which identify you.

In limited circumstances, Smart Management Systems may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by Smart Management Systems, we may collect health information about you in an emergency or otherwise with your consent.

We may collect personal information about children (for example, when children participate in events we are involved with). Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf.

You can always decline to give Smart Management Systems any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.

Visitors to our websites

The way in which we handle the personal information of visitors to our websites is discussed below.

Business Information

Information that is collected by Smart Management Systems is considered confidential business information. Business information includes app data, task data, messages, files, contact lists, and any other business information you provided when using the Smart FOM or any other product.

We will collect and use business information only as necessary to appropriately support the Service, for the purpose of anticipating, diagnosis, supporting or resolving any problems that might limit or disrupt the quality of our customers’ service experiences or as required by law.

We build or give access to administrative tools that allow Smart Management Systems employees to view business information for the purpose of providing technical support and training. You should be aware that any personally identifiable information you submit to your Smart FOM profile can be read, collected or used by the Administrative staff at your academy or flight school.

Session Records

To maintain our quality of service and to assist in the analysis of product performance, we may also gather data on connection information, including the timing and size of all packets sent over the internet during a session. The gathered data is used only to ensure the highest quality experience possible when using Smart Management Systems’ products.

Security Information

Smart Management Systems also collects certain standard information about your computer for security and identification purposes. This information may include: IP addresses, domain names, access times, cookies and other unique identifying information, This information is used to the operation of Smart FOM and related products to identify and protect our customers and to control unauthorised use or abuse of the Service.

How and why does Smart Management Systems collect and use your personal information?

Smart Management Systems collects personal information reasonably necessary to carry out our business, to assess and manage our clients' needs, and provide services including flight school management, staff and student profiles (which will include, names, addresses, email addresses, dates of birth, medical information etc), lesson records, aircraft records, scheduling, qualification and accounts management. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing client relationships.

The purposes for which Smart Management Systems usually collects and uses personal information depends on the nature of your interaction with us, but may include:

• Improving our services and collecting demographic information;
• Responding to requests for information and other general inquiries;
• Managing, planning, advertising and administering programs, events, competitions and performances;
• Researching, developing and expanding our facilities and services;
• Informing you of our activities, events, facilities and services;
• Recruitment processes (including for volunteers, internships and work experience); and
• Responding to enquires and complaints.

Smart Management Systems generally collects personal information directly from you when you create your profile. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:

Smart Management Systems also collects and uses personal information for market research purposes and to innovate our delivery of products and services.

How does Smart Management Systems interact with you via the internet?

You may visit our websites smartaviation.net without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to Smart Management Systems will be managed in accordance with this Privacy Policy.

Surveys

In addition to required member information, we may conduct surveys and ask users to volunteer demographic information to be used on an aggregate basis for internal market research, presentation to advertisers and joint research projects with outside companies involved in product development. We use such information to better focus our product and personalize the scope of services offered to each individual user.

Web and Mobile Analytics

We continuously improve our Sites and Apps and utilise different analytic tools to help us do so, such as cookies and web beacons. We are interested in how visitors use our products, what they like and dislike, and where they have problems. We also use analytic tools on our apps to help gather non-personally identifiable data about download and application usage. In our use of analytics tools we do collect general geographical data, but it is only on an aggregate basis and not specific to an individuals exact location. These tools may be provided by third parties in order to assist us in collecting the information.

Web Beacons

Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. Web beacons are embedded invisibly on web pages.

The web beacons used in connection with our web analytics services do no share any personally identifiable information about our website visitors with third parties. These tools may gather data such as what browser you use, what operating systems are used, what is downloaded and what content is reviewed when visiting or registering for services at one of our web sites.

This information is used solely to assist Smart Management Systems to maintain a more effective and useful website for you. We track aggregate traffic patterns throughout the website but we do not correlate this information with personally identifiable data about individual users. We also track domain names, browser types and MIME type.

Cookies

Smart Management Systems' websites use cookies. A “cookie” is a small file stored on your computer's browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites.

You are not identifiable from such information. These cookies enable you to enter the Smart FOM or Smart Management Systems websites without having to log on each time. We do not store passwords or any personal information about you in the cookies.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.

Social Media

Smart Management Systems may include social media features, such as the Facebook like button and Facebook Connect. These features may collect your IP address, which page you are visiting and may set a cookie to enable the Feature to function properly. These services will also authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our signup form. Your interactions with these features are governed by the Privacy Policy of the company providing them.

Testimonials

With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can connect us via one of the methods lists in this Privacy Policy.

Third Party Websites

Smart Management Systems’ websites may contain links to third-party websites. Smart Management Systems is not responsible for the content or privacy practices of websites that are linked to our website.

Can you deal with Smart Management Systems anonymously?

Smart Management Systems will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for Smart Management Systems to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

How does Smart Management Systems hold information?

Smart Management Systems stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.

Smart Management Systems maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.

We will retain your information for as long as your account with Smart Management Systems is active or as needed to provide you the Smart FOM service. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We take steps to destroy or de-identify information that we no longer require.

Does Smart Management Systems use or disclose your personal information for direct marketing?

Smart Management Systems may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.

If you opt-out of receiving marketing material from us, Smart Management Systems may still contact you in relation to its ongoing relationship with you.

Except in accordance with this Privacy Policy, Smart Management Systems will never voluntarily share personally identifiable information with any third party without the users express consent or unless compelled by state and federal laws. Smart Management Systems reserves the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process served on our website.

How does Smart Management Systems use and disclose personal information?

For clients

The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.

For customers and participants

If you are a customer or participant in an event, we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.

Disclosure to contractors and other service providers

Smart Management Systems may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for processing credit card payments, data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.

Personal information may also be shared between related and affiliated companies of Smart Management Systems, located in Australia and overseas.

Third parties to whom we have disclosed your personal information can only use this information in accordance with this Privacy Policy and they may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

In the event that Smart Management Systems or Smart FOM or substantially all of their assets are acquired, customer information will be one of the transferred assets. If this occurs you will be notified.

Use and disclosure for administration and management

Smart Management Systems will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

• administering billing and payments and debt recovery;
• planning, managing, monitoring and evaluating our services;
• quality improvement activities;
• statistical analysis and reporting;
• training staff, contractors and other workers;
• risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
• responding to enquiries and complaints regarding our services;
• obtaining advice from consultants and other professional advisers; and
• responding to subpoenas and other legal orders and obligations.

Other uses and disclosures

We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

Does Smart Management Systems disclose your personal information overseas?

Smart Management Systems is a global organisation and works with clients, service providers, sponsors and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients.

Unless we have your consent, or an exception under the APPs applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.

Entities which are related entities of Smart Management Systems, or are otherwise affiliated with Smart Management Systems, have operations in the European Union. These recipients will be subject to GDPR obligations.

How can you access or seek correction of your personal information?

You are entitled to access your personal information held by Smart Management Systems. If you wish to change, review or deleted your personal information , you may do so through your account profiles on the Smart FOM program. Or you may make a request to Smart Management Systems. To request access to your personal information please contact our Privacy Officer using the contact details set out below.

You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.

However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

How does Smart Management Systems protect your information from loss, misuse or alteration?

Smart Management Systems uses industry-standard efforts to safeguard the confidentiality of personally identifiable information, including (among others) encryption and firewalls. Nevertheless, no security measure is perfect. Smart Management Systems is not liable for loss of passwords due to user carelessness.

If you lose control over your password, you may lose control over your personally identifiable information. If you believe that your password has been compromised, you should immediately change your password. You can do this via the Smart Management Systems’ website.

What should you do if you have a complaint about the handling of your personal information?

You may contact Smart Management Systems at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to the Privacy Officer at the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Smart Management Systems may have breached the APPs or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.

How changes are made to this Privacy Policy?

Smart Management Systems may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

If we plan to use your personally identifiable information differently from that stated at the time of collection, we will notify you via email prior to the changes taking effect. If Smart Management Systems or any of its assets are acquired by another company, we will notify you via email about this transaction and the transfer of your personal information. You will have a choice as to whether or not you consent to the usage of your personal information in a different manner.

If we make any material changes to our privacy practices that do not affect user information already stored in our database, we will post a prominent notice on our website notifying users of the change.

How can you contact Smart Management Systems?

The contact details for Smart Management Systems are:

Smart Management Systems Privacy Officer

• Nathan James
• Level 19, 10 Eagle Street, Brisbane, QLD 4001
• info@smartaviation.net
• 07 3303 0326