This Privacy Policy explains how TrustFlight Limited (‘TrustFlight’) may collect, use and disclose information we obtain through the ‘Service’.

Note: By accessing or using the Service, you expressly consent to TrustFlight’s collection, use and disclosure of your Personal Information in accordance with the terms and conditions of this Privacy Policy.

Categories of Personal Data Processed by TrustFlight

Personal data that is processed when you create a TrustFlight account:

When you create a TrustFlight account, we ask you to provide an email address and your name and a role.

Purposes & legal grounds for collection/processing

1. We process your email address because you use your email address and password to sign in to your account to use the Service. The legal grounds for processing your email address is for the purpose of security and protecting your account.
2. Email addresses are also used for the purpose of sending important information and updates about the Services or your account such as information relating to safety or changes to this Privacy Policy.
3. Your name is processed as part of the account information. This is used for account identification and for regulatory requirements against any records which are created and modified by you.
4. Your role is processed as part of the account information. This is used for account identification and permissions as required by regulatory requirements to control access to records.
5. If you opt-in to receiving marketing information from TrustFlight, we will also process your email for the purpose of sending you marketing information. The legal grounds for processing this information is your consent. You may withdraw your consent at any time by changing your preferences and using the unsubscribe link on any of the emails received.
6. TrustFlight will also process your email address when you interact with our customer support team. The legal grounds for this is providing you a suitable level of product support.

Personal data that is processed when you use add an aircraft to the service:

When you add an aircraft to your account, we will ask for information on the model, registration, year and serial number of the aircraft.

Purposes & legal grounds for collection/processing

1. The information is processed to help identify an aircraft, and link any logs created to existing records. The legal grounds for processing this information is our interest in providing a product which records accurate information against each aircraft.
2. This information is also used within the Service to enable users to correctly log any information against the correct aircraft. The legal grounds for processing this information is our interest in providing correct and complete records against aircraft.

Personal data that is processed when you create a record using the service:

When you create a record, we process information about your flights, such as the crew members, takeoff and landing airports, dates, times, servicing items and details of any discrepancies. For each record created and any changes, we process a copy of your signature.

Purposes & legal grounds for collection/processing

1. We process this data as part of the Service to create and maintain records required by regulations. The legal grounds for processing this information is our interest as a provider of record keeping services.

Personal data that is processed when you use the applications:

When you use the TrustFlight iOS or Web App, we process information about you and you device including your Device ID, IP address, mobile software and hardware information, web browser information, country, language, name of mobile network and a record of pages or areas visited and the time those pages or areas were visited. You may also permit the Service to access photo storage on your device.

Purposes & legal grounds for collection/processing

1. We process this data to provide you with the best possible product experience. The legal grounds for processing this information is our interest in providing and continuously improving the product based on usage patterns.

Personal data that is processed when you communicate with TrustFlight:

When you interact with TrustFlight representatives for sales or support, we collect personal data such as your name, address, phone number, email address and information about TrustFlight products you use or are looking to use.

Purposes & legal grounds for collection/processing

1. We use this information to provide you with sales and support for our products. The legal grounds for processing this information is our interests in providing a quality level of support and sales for our products.

Personal data that is processed when you apply for a role at TrustFlight:

When you apply for a role at TrustFlight, we collect information you provide in applying for a job, including information contained on CVs or other documentation voluntarily provided by you to us throughout the job application process.

Purposes & legal grounds for collection/processing

1. We use this information to evaluate you for a role at TrustFlight. The legal grounds for processing this information is our interest in hiring suitable candidates.

Categories of Recipients of Personal Data

Other users:

TrustFlight uses aircraft information provided to help other users associate their records with the correct aircraft. Information used is the model, registration, year and serial number of the aircraft.

Disclosures:

We may disclose personal data about you to others:

1. If we have your valid consent to do so
2. to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation
3. to enforce any of our terms and conditions or policies
4. as necessary to pursue available legal remedies or defend legal claims

If we are involved in a merger, acquisition, financing due diligence, re-organisation, bankruptcy, receivership, sale of TrustFlight assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or court. We cannot control how such entities may use or disclose such information, and we disclaim any liability arising out of such entity’s failure to comply with the terms of this Privacy Policy.

Cookies and Similar Technologies

Website and web app:

To analyse how you navigate and use TrustFlight’s Website and Web App, we record information including IP address, location, browser type, language, date and time and details of the pages you view and interact with in order to identify problems and provide you with the best experience. We may use cookies, pixel tags, web beacons and other similar tools to assist in collecting and analysing this information.

If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.

If you reside in the European Union or other jurisdiction that requires us to obtain your consent to use cookies on our sites, then you will have the opportunity to manage your cookie preferences on the sites; except in certain circumstances where cookies are required to enable core site functionality. In these cases, you cannot disable those cookies.

Mobile app:

We collect data from users about their usage of the TrustFlight mobile app. The types of data collected included the date and time the app accesses our servers, app version, location of the device, language, country, information and files downloaded, device model, hardware and operating system information, user behaviour and information relating to the function of the app (such as crash reports). This data is used to monitor the functionality of the app, and provide improvements and fixes as quickly as possible.

The legal grounds for processing this information is our interest in understanding how users interact with our products and how well they are functioning so we can provide a quality service.

Analytics services:

Google Analytics is used to track site statistics and user demographics, interests and behaviour on our websites. For more information, see the Google Privacy Policy (https://support.google.com/analytics/answer/6004245). You may opt out at https://tools.google.com/dipage/gaoptout.

Hotjar is used to monitor interests and behaviour on our websites and applications. We use the information for improving our software and services. For more information, see the Hotjar Privacy Policy (https://www.hotjar.com/legal/policies/privacy/).

SmartLook is used to monitor the behaviours on our websites and applications. We use the information for improving our software and services. For more information, see the SmartLook Privacy Policy (https://help.smartlook.com/en/articles/3244452-privacy-policy).

Information Security

We endeavour to ensure that your information is treated securely and in accordance with this Privacy Policy, although due to the nature of the internet, we cannot warrant the security of any information provided to us. Neither TrustFlight, nor its affiliates, nor any of their respective employees, officers or agents or the provider of Internet services on behalf of TrustFlight can give any representation or warranty as to the absolute security of the data transmitted using the Service, and cannot give any guarantee that such data will not be compromised by bad actors. If you choose to provide data or allow collection of data by TrustFlight, then you do so understanding the aforementioned risk.

By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you.

Marketing

We do not sell, rent or share Personal Information about you with other people or non-affiliated companies for their direct marketing purposes. We may allow access to other data collected by the Service to send information we think may be relevant or useful to you. We may use your name, usage and email address without further consent for non-marketing or administrative purposes.

Legal and Similar Disclosures

We may access, preserve, and disclose collected information if we believe doing so is required or appropriate to:

1. comply with a valid subpoena, legal order, court order, legal process, or other legal obligation or law enforcement request
2. respond to your requests
3. comply with the law
4. investigate, prevent, take action, or enforce compliance with regard to a violation of this Privacy Policy
5. investigate, prevent or take action against suspected illegal activities or fraudulent behaviour
6. protect your, our, or other’s rights, property or safety

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and services, as we improve our current products and services, and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the date last updated at the top of this page. Any changes will be effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the TrustFlight website and any of our associated apps.

Storage of Personal Data

We will store your personal data using servers in different locations around the world, some of which may be outside of the European Union. If you reside in the European Union, you have the right under the General Data Protection Regulation to opt out of this. Please see ‘Your Rights’ below for details of how to do this.

Retention of Personal Data

We will retain your personal data as long as your TrustFlight account is active. Aircraft information including the model, registration, year and serial number may continue to be retained unless requested to be erased. Please see ‘Your Rights’ below for a description of your right of erasure.

Data Controller and Data Protection Officer

The personal data collected by TrustFlight is controlled by TrustFlight Limited’s Data Protection Officer at TrustFlight, 34 Hamilton Terrace, Leamington Spa CV32 4LY. You can also contact the Data Protection Officer by email at data@trustflight.com.

Your Rights

If you reside in the European Union, you have the right under the General Data Protection Regulation to request from TrustFlight access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you may have similar rights under your local laws.

To request access to or rectification, portability or erasure of your personal data, or to delete your TrustFlight account, email data@trustflight.com.

If you live in the European Union and you wish to exercise your right to restriction of processing or your right to object to processing, contact TrustFlight’s Data Protection Officer at TrustFlight, 34 Hamilton Terrace, Leamington Spa CV32 4LY or by email at data@trustflight.com. If you do not live in the European Union, but you believe you have a right to restriction of processing or a right to object to processing under your local laws, please contact TrustFlight at data@trustflight.com.