Privacy Policy

1. Who operates Pilotio

Pilotio is operated by Michal Stuchlík, self-employed individual (OSVČ), Company ID (IČO) 03868427, with its seat at Skřečoňská 1334, 735 53 Dolní Lutyně, Czech Republic.

Contact for privacy matters: support@pilotio.eu.

2. Roles: controller and processor

For data a passenger enters for a specific booking with a specific pilot, the chosen pilot / company is the controller and Pilotio is a processor acting on the pilot's instructions and under a data processing agreement.

For Pilotio's own activities (operating pilot accounts, subscriptions, security, running and developing the service) Pilotio is the controller.

3. Pilot account data

For registering and running a pilot account we process:

• login e-mail and password (stored as a secure hash),
• display name, nickname and public booking code,
• optional profile fields (photo, bio, phone, location text, language),
• the assigned plan and, for paid plans (both individual and Company), subscription identifiers held by the payment provider,
• optional mobile push notification sign-up: technical identifiers for one specific device/browser (a "push subscription" — an endpoint address and encryption keys), used only to deliver a technical notification through your browser's or operating system's own push service; these third parties never see the content of a notification (e.g. that you have a new booking), only deliver it to the device.

Legal basis: performance of the contract to use Pilotio; for optional fields (profile, mobile push notifications), legitimate interest / consent depending on which optional field is involved.

4. Passenger booking data

Passengers do not create an account. When booking, a passenger enters first and last name, e-mail, phone, weight and confirmation of the required declarations. A booking is also associated with the chosen pilot and offer, the takeoff site, the flight slot, the voucher and its validity, the booking status and its history.

Weight is required to choose the wing and equipment and to conduct the flight safely.

The booking form does not ask for diagnoses, medication, medical history or other detailed health information, and Pilotio is not designed to collect or require such data about a passenger — please do not enter health data (diagnoses, medication, medical history) into any field in Pilotio. Instead, when booking, the passenger confirms that they will inform the pilot or instructor directly, before the flight, of any relevant health limitations or other circumstances.

Older bookings (created under the consent wording in effect up to version v1, see the consent_document_version stored with the booking) may have carried a general confirmation of fitness to fly as part of the combined consent — a simple yes/no confirmation with no specific health data attached (no diagnosis, medication, etc.), and historical bookings retain this record unchanged. The current wording (from version v2) replaced that confirmation with the non-medical notification duty described above.

Legal basis: performance of the contract with the pilot / company and legitimate interests (client records, defence of claims, safe operation).

5. Operational and security data

For secure and reliable operation we process technical data: timestamps, limited abuse-protection logs and infrastructure operation logs.

We store the IP address for selected legal actions — creating a booking and confirming passenger and pilot legal declarations — as limited supporting evidence that the confirmation actually took place, and for preventing and investigating abuse or fraud and for the establishment, exercise or defence of legal claims. We do not store the IP address for any other purpose (e.g. behavioural tracking), and do not expand its collection beyond this purpose.

Legal basis for the IP address held with legal confirmations: Pilotio's legitimate interest in evidencing acceptance of legal documents and in protecting the service and its users against abuse, or compliance with legal obligations. Retention follows the criterion set out for legal-declaration confirmations in section 9 (Retention) — the IP address is kept together with, and expires together with, the confirmation it is attached to.

Legal basis for other operational and security data: legitimate interests (protecting the service and its users), or compliance with legal obligations.

6. Payments and subscriptions

Paid plans, both individual and Company (paid by the company's owner or their designated billing manager), are processed by an external payment service provider. Pilotio does not store payment card numbers. For a paid plan we process the customer and subscription identifiers, the subscription status (incl. the chosen renewal period and currency) and the data needed to issue a tax document.

Legal basis: performance of the contract and compliance with legal obligations (accounting and tax law).

7. Recipients and processors

Personal data may be made available to:

• the selected pilot / company (for passenger bookings),
• the passenger, to the extent needed for their booking,
• infrastructure and service providers acting as processors: application hosting, database and authentication, file storage, sending transactional e-mail, payment processing, and — if you enabled mobile push notifications — your browser's or operating system's own push service (e.g. Apple, Google, or Mozilla), which delivers only the technical notification, never its content,
• public authorities, where required by law.

If you contact us directly (support e-mail, the "Report a problem" form), we process the content of that communication and your contact details in order to resolve your question or issue, for as long as needed to handle it and for a reasonable period afterwards in case of follow-up correspondence; the legal basis is a legitimate interest in handling the request, or performance of the contract where the question concerns your account or subscription.

We do not sell data and do not share it for third-party advertising. To show weather, Pilotio calls an external forecast service using only the takeoff-site coordinates, not passenger personal data.

8. International transfers

Some providers may process data outside the EU/EEA. Where that happens, the transfer relies on appropriate safeguards under the GDPR, in particular the European Commission's Standard Contractual Clauses, or on an adequacy decision.

For a pilot established in Switzerland, the processing of their own and their passengers' personal data may, alongside the GDPR, also be subject to the Swiss Federal Act on Data Protection (FADP), which is a separate legal regime with its own requirements (e.g. on the definition of personal data, data-subject rights, or cross-border transfers) — compliance with the GDPR does not by itself guarantee compliance with the FADP, and Pilotio has not carried out a separate FADP compliance assessment. A pilot established in Switzerland to whom the FADP applies should assess its specific requirements themselves or with legal advice.

9. Retention

We keep data only for as long as necessary for its purpose, based on the following criteria:

• pilot account and profile: for the duration of the account; after it is closed, only for a reasonable period needed to complete related processes (e.g. a subscription running its course), unless the pilot requests deletion sooner,
• passenger booking data and the pilot's client records: for the period the pilot, as controller, determines having regard to their own legal claims and their own statutory retention duties — Pilotio does not decide this period itself; the pilot may request deletion at any time to the extent they are entitled to as controller,
• a voucher: until the end of its validity and a reasonable period afterwards in case of a complaint,
• confirmations of legal declarations (both passenger and pilot), including the IP address stored with that confirmation (see section 5), kept as evidence of acceptance: for as long as that evidence may reasonably be needed, ordinarily for the duration of the related booking/account and a further period corresponding to ordinary limitation periods under the governing law — we do not state a specific number of years here, as it varies with the law governing the particular relationship,
• records of a pilot's subscription payments: for the period required by the accounting and tax law Pilotio, as an operator seated in the Czech Republic, is subject to,
• infrastructure security and operational logs: short-term, to the extent needed to run and protect the service.

Retention criteria for data where the pilot (not Pilotio) is the controller are set by the pilot in line with their own statutory obligations — Pilotio, as processor, follows their instructions and deletes or returns data under the Data Processing Agreement (DPA).

10. Your rights

You have the right to access your data, to rectification, erasure, restriction of processing, data portability and the right to object to processing based on legitimate interest. Where processing is based on consent, you can withdraw it at any time with effect for the future.

For passenger booking data, the first point of contact is the pilot / company as controller. For pilot account data and service-operation data, exercise your rights directly with Pilotio at support@pilotio.eu.

11. Is providing the data mandatory?

The data needed to create and run a pilot account (login e-mail, password, display name) and the data a passenger needs to provide to create a booking (name, e-mail, phone, weight, confirmation of the declarations) are necessary to perform the contract to use Pilotio, respectively to arrange the flight booking. Without this data the account or the booking cannot be created. Other data (e.g. optional pilot profile fields) is voluntary; not providing it does not limit the account's or booking's functionality, it only reduces the information available to the other side.

12. Supervisory authority

If you believe that the processing of your data infringes the law, you have the right to lodge a complaint with a supervisory authority — typically in the country of your habitual residence, place of work, or the place of the alleged infringement.

For matters where Pilotio is the controller (pilot account, service operation and security data), the competent authority in the Czech Republic is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Prague 7, www.uoou.gov.cz.

For matters where the pilot / company is the controller (your booking data), a complaint primarily concerns the supervisory authority competent for that controller's seat or activity, which need not be in the Czech Republic.

13. Security

We use technical and organisational measures appropriate to the risks: database-level access control, separation of pilot and passenger roles, encrypted transport, storing passwords as a secure hash and limiting data access to necessary cases.

14. Changes and document version

We may update this policy. Material changes will be announced in an appropriate way — a pilot or passenger affected by a change may be asked to re-confirm that they have read the current text. Each document states its last-updated date and an internal version identifier (currently v3), which is recorded with every acceptance as evidence of which text was agreed to.