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Privacy Statement

Last updated on November 15, 2021.

CAE Inc. and its affiliates (collectively “CAE”, “we” or “our”) take privacy seriously. We are committed to conducting business and providing services in a way that complies with applicable privacy and data protection laws and regulations in every country in which CAE operates. This Privacy Statement describes how we process personal information and personal data (collectively “Personal Information”) in the context of our operations. It also provides information about your rights and how you can contact us if you have questions about how we handle your Personal Information.

Please click on the headings below to explore topics that are of interest to you.

About CAE

CAE is a high technology company, at the leading edge of digital immersion, providing solutions to make the world a safer place. Backed by a record of more than 70 years of industry firsts, we continue to reimagine the customer experience and revolutionize training and operational support solutions in civil aviation, defense and security, and healthcare. We are the partner of choice to customers worldwide who operate in complex, high-stakes and largely regulated environments, where successful outcomes are critical. We have the broadest global presence in our industry, with approximately 11,000 employees in 180 sites and training locations in over 35 countries. For an overview of our worldwide presence, please click on this link: https://www.cae.com/worldwide-presence/.  

Scope of application of this Privacy Statement

This Privacy Statement applies when CAE processes Personal Information in the context of its operations as a data controller (or the equivalent terminology under applicable law). As such, Personal Information may be processed in the following circumstances, namely:

  1. When you interact with us as customer, supplier, contractor or business partner;
  2. When you apply for a job at CAE or submit an application through our placement services for aviation professionals on behalf of our corporate clients;
  3. When you visit the sites managed by us or under our control, including websites, portals, software applications, social media sites and learning management systems (“CAE Sites”)
  4. When you attend a CAE event or webcast or when you communicate with us, whether by telephone, electronically or otherwise.

Please do not provide us with any Personal Information if you do not agree with this Privacy Statement.

CAE’s Sites may contain links to the sites of third parties or parts of their sites. However, CAE has no control over the content or operation of these sites, nor does it control the confidentiality or privacy practices of the site operators. Consequently, any personal information you submit through such sites is governed by the privacy policies of the sites in question. It is therefore your responsibility to find out about their policies in order to protect information that concerns you.

What Personal Information we collect

CAE may collect the following Personal Information depending on the nature of our interactions:

  • Basic contact information such as name, mailing and email addresses and telephone numbers;
  • Compliance-related information such as nationality, residency, date/place of birth, passport details and/or driver’s license details or alternatively details from similar identification documents;
  • Information related to the delivery of our services and solutions such as information provided to us by or on behalf of our clients or generated by us in the course of providing our training services and operational support solutions; 
  • Recruitment-related information such as education, academic results, experience, curriculum vitae, references, and skill checks, where applicable;
  • Financial information such as payment related information, bank account details or credit card information;
  • Photos, video and audio information including video recording through video surveillance systems when accessing CAE Sites and certain controlled areas and video and audio recording through training debriefing systems;
  • Login user credentials such as usernames, passwords, and password hints;
  • Website usage and other technical information such as computer internet protocol (IP) address, unique device identifier and other information linked to a device, information about usage of our sites collected through cookies or other tracking technologies;
  • Other personal information you provide to us such as when you submit feedback, make inquiries, contact us for support or complete surveys.
     

In some circumstances and as permitted by law, we also collect Personal Information that may be considered “sensitive” under applicable laws, such as medical certificates and, if applicable, other health or biometric data (for example, usage of facial recognition technology for identity checks in CAE Sites or by taking your fingerprints if you are a non-US citizen seeking pilot training in the US or if your training leads to a US pilot certificate or rating).

We collect your Personal Information from you, from your employer, from our customers, from third parties or through cookies and other tracking technologies (please refer to our Cookie Policy at: https://www.cae.com/cookie-policy). We do not knowingly collect Personal Information from anyone under the age of 16.

Why we collect your Personal Information and our lawful basis for processing it

We process your Personal Information only where we are satisfied that we have a business purpose and a lawful basis for doing so. Depending on the jurisdictions in which we operate, the legal bases justifying our processing of your Personal Information may include:

  • Legal obligation: where using your Personal Information is necessary to comply with applicable laws and regulations.
  • Contract performance: where using your Personal Information is necessary to establish and perform a contract with you.
  • Legitimate interests: where using your Personal Information is necessary to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
  • Consent: where you have given consent, as required by law, to process your Personal Information.
     

Type of personal information

Business purpose for processing

Lawful bases

Basic contact information

We collect this information to verify your identity and communicate with you in the context of our services, for example, when you create a customer account or when we enter into an agreement with you or with your employer.

  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent

Compliance-related information

We collect this information to verify your identity in compliance with our statutory and regulatory obligations, such as licensing, security, export control and other requirements, as required.

  • Legal obligation
  • Consent

Information related to the delivery of our services and solutions

We collect this information to perform our services under our contract with you or your employer.

  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent

Recruitment-related information

We collect this information to enable us to process applications for employment submitted via the "Careers at CAE" or "Placement for Aviation Professionals" sections of our website and to assess your suitability for any position for which you may apply at CAE or for which we carry out placement services on behalf of our corporate clients.

  • Contract performance
  • Consent

Financial information

We collect this information to process payment transactions in connection with the purchase of our products and services.

  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent

Photos, video and audio information

We collect this information to keep CAE Sites safe and for the support of debriefing of training sessions (video & audio).

  • Legal obligation
  • Legitimate interest
  • Consent

Login user credentials

We collect this information to give you a secure access to our CAE Sites, including websites, portals, applications and systems.

  • Contract performance
  • Consent

Website usage and other technical information

We collect this information to ensure network and information security, monitor the performance of our websites, applications and systems or improve your user experience.

  • Contract performance
  • Legitimate interest
  • Consent

Other Personal Information

We collect this information to respond to any inquiry or complaint made by you or your employer

  • Legal obligation
  • Contract performance
  • Legitimate interest
  • Consent

Finally, CAE may process Personal Information to protect anyone's vital interests, perform audits and defend legal claims. Such processing will be in accordance with applicable laws.We may also process your Personal Information to perform various analyses and research, and to create dashboards and databases for business purposes, including to i) provide training insights to trainees, instructors and employers, ii) improve training delivery, iii) develop new products and solutions, iv) identify usage trends, v) enhance, improve or modify our services and vi) perform audits. When doing so, we rely on the legal basis mentioned in the above table. Otherwise, we ensure that data is anonymized or aggregated so that it is not possible to identify you.

Some of the processing activities mentioned above are based on your consent. You can provide consent by a clear affirmative action either verbally, in writing or by electronic means. CAE will provide you with the necessary information on the processing activity that requires your consent under applicable laws. Your consent is voluntary (meaning you choose whether to give it), and it can be withdrawn at any time. This will result in the termination of the processing without affecting the lawfulness of the processing that occurred prior to any consent withdrawal.

When automated decision-making and profiling is used

When you submit an application for a job through our aviation placement services for our corporate clients, you will be screened as part of the application process using technology that compares your qualifications against the job requirements. Then, a decision as to whether you proceed in the recruitment process or are rejected is made automatically as a result of that comparison. This constitutes automated decision making, which means that a decision is made by technological means without any human intervention. If you are unsuccessful, you will be able to update your information on the "Placement for aviation professionals" section of our website and reapply to be re-evaluated.

How we transfer and share your Personal Information

Because we are a global business, we may process your Personal Information within the CAE group of companies (including our controlled subsidiaries and joint ventures) which are located in different geographic locations.

We may also share your Personal Information with various categories of third parties, for example:

  • the regulators that govern certain of our activities, such as the competent authorities in civil aviation;
  • our professional advisors, including our legal counsel and auditors;
  • financial institutions that process payment transactions, such as Bank of America;
  • our service providers (e.g., Salesforce, Microsoft, Oracle, SAP, Workday, payment service providers and others) that help us run our business, including for the management of our technology assets and cloud services.

We may disclose your Personal Information to other third parties to comply with legal or regulatory requirements (e.g., audits, inspections or investigations by competent authorities), fulfil our contractual obligations, enforce our corporate policies, respond to claims, or protect anyone's vital interests. We may also disclose your Personal Information to a third party in connection with a sale or transfer of business or assets, a merger or consolidation, re-organization or financing of parts of our business. In the event the transaction is completed, your Personal Information will remain protected by applicable data protection laws. However, in the event the transaction is not completed, CAE will require the other party not to use or disclose your Personal Information in any manner whatsoever and to delete it.  Such disclosures will be in accordance with applicable laws.

We only transfer Personal Information to third parties in a jurisdiction recognized as providing an adequate data protection level or that have signed a contract with CAE for processing personal information in compliance with applicable laws.

Except as otherwise mentioned herein, CAE will not transfer, sell or disclose your Personal Information to any third party without your consent.

How we protect and secure your Personal Information

CAE is committed to ensure, that your Personal Information is processed securely and accessible only by authorized persons. We have internal policies and controls in place to prevent your Personal Information from being lost, accidentally destroyed, misused, unintentionally disclosed, or accessed other than by our employees or third parties hired by CAE. We also provide mandatory training to CAE employees to raise awareness on our policies and procedures designed to manage information security threats. CAE has in place a cybersecurity incident response plan.

Nonetheless, some third parties may try to access our systems or intercept transmissions or communications unlawfully. CAE continuously uses reasonable measures in line with recognized security standards to protect your Personal Information, but we cannot absolutely guarantee that unlawful actions will not occur.

How long we keep your Personal Information for

The longer that Personal Information is retained, the higher the likelihood is of accidental disclosure, loss, theft and/or information growing stale (rendering it inaccurate). At CAE, your Personal Information is retained for no longer than necessary to support the business purpose for which it was collected or to comply with applicable laws. Afterwards all Personal Information will be deleted or anonymized as applicable. CAE periodically reviews the need for certain Personal Information processed.

Your data protection rights

Under certain circumstances and in accordance with applicable laws, you may have the right to require us to:

  • provide you with further details on the use we make of your information;
  • provide you with a copy of information that we hold about you;
  • update any inaccuracies in the Personal Information we hold;
  • delete any Personal Information that we no longer have a lawful ground to use;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how we use your information whilst a complaint is being investigated.

If you believe that the processing of your Personal Information is not compliant with applicable laws or if CAE does not respond to your requests in a timely or adequate manner and in compliance with applicable laws, you have the right to lodge a complaint with the data protection authority or court. We ask that you attempt to resolve any issues with us before lodging a complaint with any data protection authority. Please refer to “How to contact CAE” for more details.

What the residents of California should know

California residents may annually request and obtain information that is shared with other businesses for their own direct marketing use within the prior calendar year. CAE does not share your Personal Information with other businesses for their own direct marketing use.

California residents have the right to direct a company not to sell their data. As CAE does not sell your Personal Information, this does not apply.

How to contact CAE

If you have any questions about this Privacy Statement or if you have questions or enquiries about how we handle your Personal Information, please contact us at:

By mail: By phone By Email

CAE Inc.
8585 Cote-de-Liesse
Saint-Laurent, Québec
H4T 1G6 Canada
Attention: Ethics and Compliance Office
(Privacy and Data Protection)

+1 (514) 341-6780 (Extension 3824) [email protected]

When you e-mail us please remember that the content of your e-mail is not secure and could be intercepted. Accordingly, please keep the amount of confidential or Personal Information to a minimum and we will do likewise when we reply.

CAE’s designated representatives in the EU/EEA and the United Kingdom

EU/EEA representative

In the event that Personal Information is processed by a CAE entity which is not established in the European Economic Area (EEA) covered by the EU General Data Protection Regulation, our EU/EEA representative is:

CAE Parc Aviation Ltd.
Unit 2.1, Block 2, Woodford Business Park
Santry, Dublin D17 E925 Ireland

UK representative

In the event that Personal Information is processed by a CAE entity which is not established in the United Kingdom is covered by the UK General Data Protection Regulation and the Data Protection Act 2018, our UK representative is:

CAE STS Ltd.
Innovation Drive, West Sussex
Burgess Hill RH15 9TW United Kingdom

The laws and regulations governing personal information are frequently changing. CAE may update and amend this Privacy Statement from time to time.