28. Purpose of this Privacy Notice

This Privacy Notice explains how Pilot Pathway collects, uses, stores, protects and discloses Personal Information in connection with its aviation professional networking and career services. Pilot Pathway intends to process Personal Information in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and other applicable South African law.

29. Responsible Party

The responsible party for Personal Information processed through Pilot Pathway is PilotApps. Website: https://pilotpathway.co.za. For all privacy enquiries, including requests and complaints, please use the Contact Us form on this page.

30. Whose Information We May Process

Pilot Pathway may process information relating to: pilots; aviation professionals; Members; recruiters; airline representatives; employers; website visitors; account holders; support contacts; and service providers.

31. Information We May Collect

Depending on the services and functionality used, Pilot Pathway may collect:

Identity and Profile Information:

• name
• photograph
• professional headline
• country
• general location
• nationality
• gender
• date of birth

Professional Information:

• current position
• current employer
• current base
• preferred career path
• professional biography
• licences
• ratings
• aircraft experience
• career history
• training-bond information

Contact Information:

• professional email address
• WhatsApp or mobile number

Medical Certification Category:

Where provided, Pilot Pathway may process a limited certification category such as Class 1, Class 2, Student Medical or Not Specified. Pilot Pathway does not require Members to place detailed medical histories or diagnoses in ordinary professional profiles.

Private Documents:

Members may upload aviation-related documents to a private document area. These documents are not automatically made available to recruiters.

Technical Information:

Depending on Platform configuration, Pilot Pathway may process IP address, browser information, device information, operating system, timestamps, security logs, cookies and analytics information.

32. Why We Process Personal Information

Pilot Pathway may process Personal Information to: create and manage accounts; operate professional profiles; provide professional networking; enable recruiter discovery; facilitate career opportunities; allow authorised recruiter contact; provide Platform services; maintain security; prevent fraud; investigate reports; provide customer support; maintain audit records; improve Platform functionality; comply with legal obligations; and protect legal rights.

33. Professional Profile Disclosure

The principal purpose of Pilot Pathway is to facilitate aviation professional networking, career discovery and connections between aviation professionals and authorised aviation organisations. Where a Member enables professional-profile visibility, selected information may be made available to authorised employers, recruiters and other authorised aviation organisations. Depending on the Member's settings, this may include professional name, photograph, professional headline, location, professional information, aviation qualifications, relevant experience, contact information, and other permitted fields selected by the Member. Private documents are not automatically disclosed through ordinary profile visibility.

34. Member-Controlled Visibility

Pilot Pathway is designed to give Members meaningful control over information displayed to recruiters. Where the functionality is available, Members may show or hide their entire professional profile, show or hide permitted profile categories, review their recruiter-facing profile, and change visibility settings. Pilot Pathway will apply the Member's visibility settings to recruiter access, subject to technical limitations and information that Pilot Pathway is legally required to retain or disclose.

35. Date of Birth

Pilot Pathway may collect a Member's date of birth primarily to verify the 18+ age requirement, calculate age where necessary, and provide age-related functionality. The full date of birth should not ordinarily be displayed to recruiters.

36. Nationality

Nationality may be collected where there is a legitimate professional or recruitment-related purpose. Pilot Pathway will seek to minimise unnecessary exposure of nationality and will not ordinarily make nationality a mandatory recruiter search criterion unless there is a legitimate and lawful reason. Where appropriate, work-authorisation information may be more relevant than nationality.

37. Gender

Gender should be optional. Where provided, available options may include Male, Female, Other, or Prefer not to say. Gender should not be required merely to create a professional profile. Pilot Pathway will not ordinarily expose gender as a recruiter search or filtering field unless there is a legitimate and lawful reason.

38. Medical Information

Pilot Pathway limits ordinary professional medical information to a certification category where applicable. Members should not enter detailed medical information into ordinary professional-profile fields. Where information constitutes special personal information under applicable law, Pilot Pathway will apply appropriate safeguards and lawful-processing requirements.

39. Private Documents

Private documents remain private by default. Pilot Pathway will not make a private document available to a recruiter merely because a Member uploaded it, created a profile, or enabled professional-profile visibility. Any future document-sharing functionality will require an appropriate user action or authorisation before disclosure.

40. Recruiter Contact

A Member who enables professional-profile visibility acknowledges that authorised recruiters and employers may contact them concerning employment, recruitment, aviation opportunities, career opportunities or professional opportunities. Such contact may occur even where the Member has not submitted an application for a specific vacancy. Pilot Pathway does not control the content of communications sent by third-party recruiters or employers.

41. Lawful Processing

Pilot Pathway will identify an appropriate lawful basis for processing Personal Information. Depending on the circumstances, processing may rely upon consent, contractual necessity, steps requested by the data subject, legitimate interests where permitted, legal obligations, or other lawful grounds recognised by applicable law. Consent will not be treated as the lawful basis for every processing activity where another lawful basis applies.

42. Data Minimisation

Pilot Pathway will seek to collect Personal Information that is adequate, relevant and not excessive for the purpose for which it is processed, and will seek to avoid collecting information that is unnecessary for the relevant service or purpose.

43. Information Accuracy

Members are responsible for the accuracy of information they submit and should update their information when it becomes inaccurate or materially outdated. Pilot Pathway may provide mechanisms allowing Members to correct information associated with their accounts.

44. Automated Decisions

Pilot Pathway does not currently make automated employment decisions on behalf of employers. Recruiter search and filtering functionality may allow an employer or recruiter to search for professional criteria. A search result does not mean that Pilot Pathway has determined that a Member is suitable for employment.

45. Recipients of Personal Information

Where necessary and lawful, Personal Information may be disclosed to authorised airlines, aviation employers, recruitment agencies, authorised recruiters, hosting providers, database providers, security providers, analytics providers, professional advisers, regulators, law-enforcement authorities, courts, and other parties where disclosure is legally required or permitted. Pilot Pathway will seek to limit disclosure to what is reasonably necessary for the applicable purpose.

46. International Processing

Some service providers, employers or recruiters may operate outside South Africa. Personal Information may therefore be processed or disclosed outside South Africa where lawful and where applicable legal requirements relating to cross-border transfers are satisfied. Pilot Pathway will consider applicable POPIA requirements when implementing or using international processing arrangements.

47. Third-Party Service Providers

Pilot Pathway may use third-party providers for hosting, application infrastructure, databases, analytics, storage, security, communications and authentication. Third-party providers may process Personal Information on behalf of Pilot Pathway where necessary to provide their services. Pilot Pathway will take reasonable steps to ensure that relevant service providers are subject to appropriate confidentiality, security and data-processing requirements.

48. Google Analytics

Pilot Pathway may use Google Analytics to understand website and Platform usage. Analytics information may include information concerning visitor numbers, page usage, performance, errors, feature usage and technical information. Pilot Pathway will configure analytics technologies in accordance with applicable privacy requirements.

49. Google Tag Manager

Pilot Pathway may use Google Tag Manager to manage website tags and technologies. Technologies deployed through Google Tag Manager may process information depending on the specific tags configured. Pilot Pathway will seek to maintain appropriate records of technologies deployed through its tag-management system.

50. Data Retention

Pilot Pathway will not retain Personal Information indefinitely without a lawful or operational purpose. Retention periods may depend upon account status, professional networking purposes, recruitment purposes, legal requirements, security requirements, disputes, audit requirements and backup cycles.

51. Account Deletion

Where a Member deletes an account, Pilot Pathway will remove Personal Information from active systems where technically possible and legally appropriate. Information may remain temporarily in protected backups or records where retention is legally justified or reasonably necessary. When information is no longer required, it should be securely deleted, destroyed or irreversibly anonymised where appropriate.

52. Security

Pilot Pathway will implement reasonable technical and organisational measures designed to protect Personal Information against loss, damage, unauthorised destruction, unlawful access, unauthorised processing and accidental disclosure. Security measures may include appropriate encryption, access controls, authentication controls, password protection, administrator controls, audit logging, secure backups, software updates, vulnerability management, incident-response procedures and secure deletion.

53. Security Compromises

If Pilot Pathway becomes aware of a security compromise involving Personal Information, it will assess and respond in accordance with applicable law and its incident-response procedures. Where required by applicable law, Pilot Pathway will notify the Information Regulator and affected data subjects.

54. Data Subject Rights

Subject to applicable law, a data subject may have rights including the right to request access to Personal Information, request correction, request deletion where applicable, object to processing, object to direct marketing, withdraw consent where consent is the applicable lawful basis, complain about processing, and exercise other rights provided by POPIA. The Information Regulator provides procedures and prescribed forms relating to POPIA and PAIA requests.

55. Privacy Requests

Privacy requests should be submitted through the Contact Us form on this page. Pilot Pathway may request reasonable proof of identity before processing certain requests.

56. Privacy Complaints

A complaint should first be directed to the Pilot Pathway Information Officer through the Contact Us form on this page. Where applicable, a person may also lodge a complaint with the Information Regulator.