Privacy policy

1. Person responsible

We, ProToura Holding GmbH (hereinafter also "PT GmbH", "we", "us"), inform you in the following about the processing of your personal data in the context of the use of our website www.protoura.com ("Website").

2. Scope, purpose, and legal basis of processing personal data

In the following situations, we collect and use personal data directly from our users or from other sources (as shown below):

2.1. provision of the website and creation of log files.

When users visit our website, our system automatically collects data and information from the computer system of the calling computer each time our website is called up. The following data ("technical information") is collected:

- Information about the browser type and version used

- The operating system of the user

- The user's Internet service provider

- The IP address of the user

- Date and time of access

- Websites from which the user's system accesses our website

- Websites and files accessed by the user's system through our website, as well as other information: Access type and protocol

- Size of the requested file/page

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user.

We collect and use this technical information for purposes of (network) security (e.g. to combat cyber-attacks), marketing and to better understand the needs of our users, as well as to continuously improve our website and to enable the delivery of the website to the user's computer.

The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1 lit. f DSGVO.

2.2 SSL encryption

To protect the security of your data during transmission, we use state-of-the-art encryption methods (e.g., SSL) via HTTPS.

2.1.1 Use of cookies

Our website uses cookies. Cookies are text files that are stored in the Internet browser or by the Internet browser on the user's computer system. When a user accesses a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string of characters that enables the browser to be uniquely identified when the website is called up again.

Cookies are stored on the user's computer and transmitted from it to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are deactivated for our website, it may no longer be possible to use all functions of the website in full.

2.1.2 Tracking tools

On our website we use the following tracking and (re-)marketing tools:
- Google Analytics

The legal basis for the use of the listed tools is our legitimate interest pursuant to Art. 6 (1) lit. f DSGVO for purposes of increasing the efficiency of our website and (direct) marketing.

2.1.2.1 Privacy policy for the use of Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. If IP anonymization is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link.

. http://tools.google.com/dlpage/gaoptout?hl=de.

You can prevent the collection of Google Analytics by clicking on the following link. An opt-out cookie will be set, which prevents the future collection of your data when visiting this website:

For more information on terms of use and privacy policy, please visit: http://www.google.com/analytics/terms/de.html and https://www.google.de/intl/de/policies/. We would like to point out that on this website Google Analytics has been extended by the code "anonymizeIp" to ensure anonymized collection of IP addresses (so-called IP masking) (Source: www.datenschutzbeauftragter-info.de). 

2.3 Privacy policy for the use of Google Fonts

This website uses Google Fonts (https://fonts.google.com/), which loads and provides the fonts used for the texts displayed here on your terminal device. Google Fonts is a service of the company Google Inc ("Google"). We use this service to display our content across browsers graphically aesthetically, appealing, technically correct and with the lowest possible data volume for you. For this purpose, Google Fonts are used to avoid multiple loading of the font into the cache of your browser. Should your browser prevent access, the content will be displayed in a standard font. Google does not set a cookie for the provision of the fonts, which means that data about user behavior etc. is not tracked, stored, and collected by Google Fonts, and ensures with the help of the Google Fonts API that only the absolute minimum necessary to display the font to you is loaded and stored. As part of this, it is technically essential that your IP address is given to Google Fonts for the font to be loaded on your device. You can check in your browser that no cookie is loaded for the font. Google collects, according to its own information, the aggregated number of retrievals of a font to create statistics from it and thus determine how often a font is used or not. If you do not agree with the use of Google Fonts on our site, you must please block access to Google Fonts in your browser settings, or alternatively refrain from visiting our site. You can find out more about Google's privacy policy and terms of use on the following page: https://policies.google.com/privacy?hl=de&tid=211110263

2.4 Use of the services offered on our website

We offer a variety of different services on our website. In order to provide these, we need to collect and process personal data of the user or our customer.

2.5 Our legitimate interests in the processing of personal data

The purpose of the company is the holding of investments and the conception and implementation of events, especially in the fields of aviation and aerospace, through subsidiaries in Germany and abroad and the operation of all businesses and facilities related to the purpose of the company. The collection, processing and use of data is carried out in order to pursue the above-mentioned purpose. The processing of personal data takes place in the area of customers (booking, processing, and security).

If Art. 6 (1) lit. f DSGVO is the legal basis for the processing, our legitimate interests in addition to the purposes listed above:

- The protection of the company from material or immaterial damage.

- The professionalization (of our products and services)

- Cost optimization (control and minimization)

2.6 Further processing obligations

If we are legally obligated to do so, we process personal data in order to comply with retention obligations under commercial or tax law or in order to fulfill security requirements imposed by Lufthansa Aviation Training GmbH (e.g. § 7 LuftSiG). Further information on retention periods can be found under "Duration of data processing".

2.7 Obligation to provide personal data

For legally or contractual requirements, we have marked the respective input fields in the input masks on our website that are mandatory for you to fill in so that we can provide the contract or service requested by you.

2.8 Contacting us via e-mail or contact form

If you contact us by e-mail or contact form, the information you provide will be stored for the purpose of processing the request and for possible follow-up questions. Your personal data will not be passed on to third parties for advertising purposes or for purposes other than processing your inquiry.

3. Duration of data processing

Your personal data will be deleted as soon as they are no longer required for the stated purposes. In this context, it is possible that personal data will be retained for the period in which claims can be asserted against PT Holding GmbH (statutory limitation period of three to thirty years). In principle, personal data will only be stored to the extent and for as long as PT is legally obliged to do so. Corresponding obligations to provide proof and to store data arise, among other things, from the German Commercial Code, the German Fiscal Code, and the German Money Laundering Act. The storage periods are then up to ten years.

4. Right of objection according to Art. 21 DSGVO

Right of objection according to Art. 21 DSGVO: You have the right to object at any time, on grounds relating to your situation, to the processing of personal data concerning you which is carried out based on Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions.

The controller shall no longer process the personal data concerning you unless it can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the possibility, in connection with the use of information society services - notwithstanding Directive 2002/58/EC - to exercise your right to object by means of automated procedures using technical specifications.

5. Disclosure of personal data to third parties

In case of overriding legal provisions of public authorities we must and in order to fulfill the purpose mentioned in point 4 (security control at the entrance to the simulator building) we will pass on the necessary personal data to the internal department of Lufthansa Aviation Training and its contracted security service.

To provide you with our products and services, based on our contractual obligations or according to our legitimate interests, we may need to share your personal data with third parties within the ProToura Group. These recipients can be categorized as follows:

Service provider:

- Special inquiries: ProFlight GmbH, Gerold-Janssen-Straße 5, 28359 Bremen; ProToura GmbH, Gerold-Janssen-Straße 5, 28359 Bremen; flugsimulator.com UG, Gerold-Janssen-Straße 5, 28359Bremen; ProToura Holding GmbH, Gerold-Janssen-Straße 5, 28359 Bremen

- Backoffice / Accounting: ProToura Holding GmbH, Gerold-Janssen-Straße 5, 28359 Bremen 

- IT

- Security control Lufthansa Aviation Training: primarily responsible for all locations: Lufthansa Aviation Training GmbH, Südallee 15, 85356 München Airport; subcontractor: Gegenbauer Sicherheitsdienste GmbH, Am Sälzerhof 24, 34123 Kassel.

In addition, we may be required by law to provide personal data to German and international authorities, Art. 6 para. 1 lit. c DSGVO in conjunction with local and international regulations and agreements

6. Rights of the data subject

It is an important concern for PT to ensure that our processing procedures are fair and transparent. Therefore, it is important to us that data subjects can exercise the following rights in addition to the right to object if the respective legal requirements are met:

- Right to information, Art. 15 DSGVO

- Right to rectification, Art. 16DSGVO

- Right to erasure ("right to be forgotten"), Art. 17DSGVO

- Right to restriction of processing, Art. 18DSGVO

- Right to data portability, Art. 20 DSGVO

To exercise your right, you can contact us by email at  info(at)protoura.com

To be able to process your request as well as for identification purposes, we would like to point out that we will process your personal data in accordance with Art. 6 para.1 lit. c DSGVO. 

Right to complain to the competent supervisory authority

As a data subject, you have the right to lodge a complaint with the competent supervisory authority in the event of a data protection violation. The competent supervisory authority regarding data protection issues is the state data protection commissioner of the federal state in which our company's registered office is located. The following link provides a list of data protection officers and their contact details:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html

7. Consent

If you have given us consent to process your personal data, we hereby inform you that you can revoke this consent at any time.
In all other cases or if you have problems revoking your consent on this website, you can contact info(at)protoura.com
Please note that your revocation of consent will only have effect for the future and will not affect the lawfulness of processing in the past. In some cases, despite your revocation, we are entitled to further process your personal data on another legal basis - such as for the performance of a contract.

8. Disclaimer and limits of this privacy policy

This privacy notice only covers the processing operations of the www.protoura.com website. Other websites are not covered by this privacy notice and provide their own specific privacy notices.

9. Enforcement of and compliance with this privacy statement

ProToura Holding GmbH undertakes to comply with the above points regarding data protection as described.

If you have any questions regarding the processing of your personal data you can also contact the management directly, which is also available in case of requests for information, suggestions, or complaints.

Walter Drasl
ProToura Holding GmbH
Gerold-Janssen-Straße 5, 28359 Bremen
Telefon: 0421 24 13 30 
E-Mail: walter.drasl(at)protoura.com 

Due to the size of the company, we are not obliged to appoint a data protection officer.

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