AviatorX Ltd
PRIVACY NOTICE
Purpose
AviationX Ltd trading as Club Aviator or the Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we process your personal data on our website/app where you are a user, supplier of services to us or a visitor on our website. This privacy notice also tells you about your privacy rights pursuant to Data Protection Laws such as the UK Data Protection Act 2018, the General Data Protection Regulation (UK GDPR) and the EU GDPR. Our stance is to use the GDPR as the gold-plated standard for data protection compliance.
Controller for personal data
Our platform is designed exclusively for members of the aviation community to connect, share experiences and engage with one another fostering a supportive community for networking, discussions and access to relevant services and resources. A “controller” is a person or organisation who alone or jointly determines the purposes for which and the way any personal data is or is likely to be processed. Unless we notify you otherwise, we are the controller of your personal data for the purpose of this website and the use of our platform.
Scope
This privacy notice applies to the processing of personal data by us in connection with:
- Users: Individuals who sign up to connect with each other and access various services which we may provide on our platform. A user is classed as a member in the aviation community as determined by us.
- Suppliers: For the provision of products and services to us by suppliers or service providers.
- Website visitors: Where you are a visitor on our website.
Types of personal data
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. This is known as anonymised data. Anonymised data falls outside the scope of Data Protection Laws.
Club Aviator may collect, use, store and transfer different kinds of personal data about you which we have grouped together:
- Identity Data includes first name, last name, username or similar identifier and title, role, rank (e.g. cabin crew, pilot), employer details (for verification purposes) and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details. Note where you are a user of our services, we will only take payment via the app store such as Google Pay and Apple Store, we will only see limited financial data in this respect.
- Transaction Data includes details about payments to and from you and other transaction details for the provision of services.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or platform.
- Profile Data includes your username and password, searches made by you, your ratings and comments, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Depending on your relationship with us we may process the categories of data above and categories of personal data specific to you. Please see below in the Processing Table on how we may process your personal data depending on our relationship with you and our lawful basis for doing so.
Lawful bases: How we use your personal data
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
- Performance of a contract: Where we need to perform the contract, we are about to enter into or have entered into with you. For example, when you sign up to our services to use our platform.
- Legal obligation: Where we need to comply with a legal obligation. For example, for our accounting or legal purposes.
- Legitimate interests: Where it is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests.
- Consent: Where we do rely on consent you have the right to withdraw consent at any time. Please contact us at info@clubaviator.co to withdraw consent. Please also see Marketing communications.
- Vital interests: Where is it necessary to protect your vital interests in case of emergencies.
- Public obligation: Where we need to comply with a public obligation, for example in the matters of public health or public interests.
How we collect your personal data
Directly from you: You give us your personal data in your direct interactions with us. Such personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our website (ii) by leaving ratings and comments; or (iii) by corresponding with us by email, post or by telephone.
Third-party sources: We receive Identity Data and Contact Data about you from third parties when:
- other parties send us your personal data to enable the provision of our services to you.
- you provide your personal data to a third party for the purpose of sharing it with us.
User: Processing Information
We provide our services directly to you as a member of the aviation community. To maintain a trusted and secure environment, access to the platform is limited to verified individuals within this community on a best endeavours basis. Membership may be declined where eligibility criteria are not met and in such cases, we will clearly explain the reasons for our decision.
| Processing activities | Categories of personal data | Lawful basis |
| To sign you up to our app | Identity Data, Contact Data
To sign up to our app you must have a valid work email address attributed to a verifiable email address in the aviation sector or community as approved by us |
Performance of a contract
Consent (to download our app onto your device) |
| To sign you up to our products/ services including but not limited to the use of our platform, make recommendations to you, allow you to connect with other users in the platform for example to facilitate meetups. | Identity Data, Contact Data
To sign up to our app you must have a valid work email address attributed to a verifiable email address in the aviation sector or community as approved by us |
Performance of a contract |
| To facilitate account creation and login process | Identity Data, Contact Data | Performance of a contract |
| To verify your identity and that you are a member of the aviation industry as an authorised user of our platform. | Identity Data, Contact Data (we may ask for your work email address and personal email address to verify that you can join the platform) | Performance of a contract |
| To respond to any enquires | Identity Data, Contact Data | Performance of a contract with you
Necessary for our legitimate interests |
| To process our products/services to you including manage payments, fees and charges and collect and recover money owed to us | Identity Data, Contact Data, Financial Data (Limited data via Google Pay and Apple Store), Transaction Data | Performance of a contract with you
Necessary for our legitimate interests i.e., to recover debts due to us |
| Register you for our newsletters and marketing communications | Identity Data, Contact Data | Consent (Opt-in) or Soft Opt-in (depending on which country you are located) |
| To post testimonials on our website that may contain personal information. | Identity Data | Consent – Prior to posting a testimonial we will obtain your consent to use your name and the content of the testimonial.
If you wish to update or delete your testimonial, please contact us and include your name, testimonial location and contact information |
| To administer and protect our business and our platform including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | Identity Data, Contact Data Technical Data | Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
Necessary to comply with a legal obligation |
| To include recommendations based on your feedback, likes and location data. | Identity Data, Contact Data, Technical Data such as your location where you tell us your location) | Performance of a contract |
| To allow you to connect with other members of the aviation community and facilitate meetups | Identity Data, Contact Data | Performance of a contract |
| To provide you with the best experience, our app requires access to your location. Sharing your location allows us to offer location-based features and services tailored to your needs. Please enable location access in your device settings |
Identity Data, Contact Data, Technical Data (location data) | Consent |
Uploading images and special categories of personal data
Due to the nature of our service, you may upload images and videos containing personal data (e.g. images of yourself and location data such as landmarks) at your own risk.
We do not actively process special categories of personal data – racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (used for identification purposes), health data and data concerning a person’s sex life or sexual orientation). However, you may choose to share such information on the platform. By doing so, you acknowledge that you are sharing this information voluntarily. Please exercise caution when posting personal data, as the platform is a space for open discussions. We recommend being mindful of the type of information you share to protect your privacy.
Sharing information on our platform
We are not responsible for the content you choose to share on the platform. Please ensure you follow your organisation’s policies regarding information disclosure. Only share content you are comfortable making visible to others within the app. If you’re unsure about sharing personal data, we recommend not doing so. Always use discretion and prioritise your privacy and safety when engaging with others.
Supplier: Processing Information
This is where you are a supplier of products and services to us so that we can effectively run our business.
| Processing activities | Categories of personal data | Lawful basis |
| For you to provide services and products to us | Identity Data, Contact Data, | Performance of a contract |
| Manage payments, fees and charges we owe you | Identity Data, Contact Data, Financial Data, Transaction Data | Performance of a contract with you |
| To engage with you as a customer for product/service support | Identity Data, Contact Data | Performance of a contract
Necessary for our legitimate interests so that we are able to get in touch with our queries, issues and concerns. |
Website visitor: Processing Information
This is where you are a website visitor on our website regardless as to whether you will be taking up our services.
| Processing activities | Categories of personal data | Lawful basis |
| When you contact us via our website, forms and other links on our website including AI- chat features. | Identity Data, Contact Data | Necessary for our legitimate interests where we need to be able to respond to you |
| To manage our relationship with you which will include notifying you about changes to our terms or privacy notice | Identity Data, Contact Data (where you have provided that data to us) | Necessary for our legitimate interests i.e., to keep our records updated and to study how visitors use our products/services |
| To administer and protect our business and our website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | Identity Data, Contact Data Technical Data | Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Data Contact Data, Profile Data, Usage Data, Marketing and Communications Data, Technical Data | Necessary for our legitimate interests i.e., to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical Data, Usage Data | Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
Note: Where applicable consent will be used for data analytics obtained through cookies or similar technologies. See our cookies notice |
| Use of non-essential cookies (where consent applies in a particular jurisdiction) | Technical Data | Consent |
Cookies and similar technologies
Club Aviator gathers information and statistics collectively about visitors to our website. Analysis of this information demonstrates the most frequently used sections of the website and assists us in continually improving the online service. Please also refer to our cookies notice for more information on how we set cookies.
Providing personal data
Where we need to collect personal data by law or under the terms of a contract and you do not provide that information when requested we may not be able to perform the contract we have or are trying to enter into with you for example to provide you with our services. In this case we may have to cancel our service, but we will notify you if this is the case at the time.
Marketing communications
Club Aviator may send you marketing communication. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe from receiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us.
Where you opt out of receiving marketing communications this will not apply to personal data provided to us as a result of registering for or using our service, your service experience or other interactions with this website.
How we share your personal data
We do not and will not sell any of your personal data to any third party, including your name, contact information or payment information. We may have to share your personal data with the parties set out below:
- Internally: Your personal data will be used by our employees and contractors who are working on providing your services to you on a need-to-know basis.
- Within our Group: Your personal data can be shared within our Group of companies so that we can carry out our services to you.
- Suppliers: This would include service providers who support our business including IT and communication suppliers and outsourced business support to ensure our service runs smoothly.
- Professional advisers: This would include lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Payment Service Intermediaries: These providers help facilitate payment to us.
- Law enforcement bodies, regulators and other authorities: This is to comply with our legal requirements or adhere to good practices.
- Advertising networks and analytics service providers: This is to support and display ads on our website/app and other social media tools.
Third parties: This is in the context of the acquisition or transfer of any part of our business or in connection with the business reorganisation. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
International transfers for UK/EU
We may transfer and process your personal data outside of the United Kingdom (UK) /European Union (EU) to countries where data protection laws are less stringent than those in the UK/EU. For example, our platform hosting services may be located outside the UK/EU. When we transfer your personal data outside of the UK/ EU we only do so to entities that offer our users the same level of data protection as that afforded by the UK Data Protection Act 2018 (including the UK GDPR) and the EU GDPR/ Data Protection Laws.
- We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
- We will use specific contracts approved for use in the UK or EU which give personal information the same protection it has in the UK/EU. For example, the use of Article 46 UK and EU GDPR safeguard mechanisms to transfer personal data endorsed by the UK Government or European Commission.
For other countries we will use local law guidance to ensure personal data is transferred securely where there is a requirement in law to do so.
To find out more about the transfer mechanism used please contact us at info@clubaviator.co
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal data, Club Aviator cannot guarantee the security of your information transmitted and any transmission is at your own risk.
Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Information to users on account deactivation and deletion
We will be sad to see you go, but when you decide to leave our platform, your content can be affected in different ways depending on what you choose to do with your account:
Deactivating the Account
This means your account becomes invisible to others but we may retain the data. Messages sent to others remain in their inboxes. You may reactivate at any time and this will restore your content.
Deleting the Account
If you choose to delete your account, we will permanently remove the account after a 90-day grace period. This means any personal content (photos, posts, profile info) is deleted. Messages sent to others might still exist in their inboxes.
Content Shared by Others
If you have posted something on someone else’s profile, commented on posts or was tagged in content by others that content may remain even after deletion of your account.
Data Subject Rights
Under certain circumstances, you have rights under Data Protection Laws. Not all rights are absolute and depending on where you are located, not all rights are given to you. You can:
Request access to your personal data: This is known as a “subject access request” and enables you to receive a copy of the personal data we hold about you.
Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. See also Marketing communications.
Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the information’s accuracy (b) where our use of the information is unlawful but you do not want us to erase it (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.
Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, we may not be able to provide certain services to you if you withdraw your consent. We will advise you if this is the case at the time you withdraw your consent.
Automated decision making: This is where decisions are made about you by automated means. We do not carry out automated decision making which results in legal or similarly significant effect. To enhance your experience on the app, we may use AI to suggest meet-up spots, dining options or places of interest based on your location and preferences. All suggestions are designed to support, and not decide for you. As part of our automated process, we use AI technologies to flag instances of profanity. This allows us to automatically detect inappropriate language and notify the app administrator to ensure timely review and appropriate action.
Carrying out your data subject rights
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information or to exercise any of your other rights. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of the rights set out above, please contact us at info@clubaviator.co
Keeping personal information accurate and current
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Please contact us if you wish to update your personal data.
Concerns and complaints
We would appreciate the chance to deal with your concerns in the first instance. Please see Contact us section. If you have unresolved issues, you have the right to complain at any time to a data protection supervisory authority for data protection issues such as the UK data protection regulator – the Information Commissioner’s Office (ICO).
You may lodge a complaint with a supervisory authority if you live or work outside the UK or you have a complaint concerning our personal data processing activities.
Changes to our privacy notice
This privacy notice may be changed from time to time in response to legal, technical or business developments. We will take appropriate measures to inform you when we update our privacy notice. We will obtain your consent to any material privacy notice changes if and where this is required by applicable Data Protection Laws.
Contact us
If you would like more information about the way we manage personal information that we hold about you please contact us at:
Email address: info@clubaviator.co
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This version was last updated in May 2025.