Privacy Policy

Last updated: March 25, 2026

1. Controller (Data Controller)

The controller responsible for data processing in connection with this app and website within the meaning of the General Data Protection Regulation (GDPR) is:

Tobias Maihoff
c/o Impressumservice
Stettiner Straße 41
D-35410 Hungen
Germany

Email: contact@ifrsimulator.com

2. Scope of This Policy

This Privacy Policy explains how personal data is processed when you:

  • Use the mobile application “IFR Flight Simulator” on iOS and Android devices
  • Visit the website at ifrsimulator.com

Both the app and the website are designed to operate largely without collecting personally identifiable information. The app does not require user registration for general use, though accounts may be created for participants of the Flight School Pro program (see Section 4.7). The website does not use cookies for tracking or advertising purposes.

3. Definitions

  • Personal Data— any information relating to an identified or identifiable natural person (Art. 4(1) GDPR).
  • Processing— any operation performed on personal data, such as collection, storage, use, or transmission (Art. 4(2) GDPR).
  • Controller— the entity determining the purposes and means of processing (Art. 4(7) GDPR).

4. Categories of Data Processed

4.1 Third-Party Analytics (Firebase Analytics)

The app uses Firebase Analytics, a service provided by Google LLC, to understand aggregated usage patterns and improve the app.

Possible data processed includes:

  • App usage events
  • Device information (model, operating system, language)
  • Approximate location derived from IP
  • App instance identifiers
  • Interaction data
  • Crash correlation data

Data is processed in aggregated form where possible.

Google may process data on servers located outside the European Economic Area (EEA), including the United States.

More information: policies.google.com/privacy

4.2 Crash Reports (Firebase Crashlytics)

The app uses Firebase Crashlytics to monitor stability. Data processed may include:

  • Crash logs and stack traces
  • Device type and operating system
  • App version
  • Installation UUID
  • Runtime environment information

Crash reports are used solely for technical troubleshooting and are not used to identify users.

4.3 In-App Purchase Management (RevenueCat)

RevenueCat is used to validate purchases and manage subscription status. Data processed may include:

  • Anonymous app user identifier
  • Purchase history and subscription status
  • Transaction metadata provided by Apple or Google
  • Device information
  • App version

RevenueCat does not receive payment credentials such as credit card details.

More information: revenuecat.com/privacy

4.4 Payments Processed by Platform Providers

All payments are handled exclusively by:

  • Apple Inc. (App Store)
  • Google LLC (Google Play Store)

These providers process payment data independently as controllers. The developer does not receive or store payment details.

4.5 IP-Based Geolocation (ipapi.co)

To center the map on startup, the app may determine an approximate location using an external geolocation service operated by Kloudend, Inc. (ipapi.co), USA.

Processing involves:

  • Transmission of the device’s IP address
  • Determination of approximate geographic location
  • Return of coarse coordinates or regional data

No precise GPS location is used. The developer does not store or track the returned location.

More information: ipapi.co/privacy

4.6 Anonymous Flight Data

The app may collect and store anonymized flight data to improve the app experience, analyze usage patterns, and create aggregated content for social sharing and marketing purposes.

Data collected may include flight parameters such as paths, altitudes, procedures flown, and performance metrics. No data that could identify an individual user is included.

This data:

  • Is fully anonymized — it cannot be linked to an individual user
  • Does not include device identifiers, IP addresses, or location data
  • May be used in aggregated form for app optimization and feature development
  • May be used to generate statistics, visualizations, or content for social media and marketing — both aggregated (e.g., “10 million approaches flown”) and as individual anonymized flight examples (e.g., showcasing a specific approach or holding pattern)
  • Will never be sold to third parties

Processing is based on legitimate interests (Art. 6(1)(f) GDPR) in improving the app and communicating its usage to prospective users. You can opt out of this data collection at any time in the app settings.

4.7 Flight School Pro Accounts

For users participating in the “Flight School Pro” program, user accounts may be created and managed. These accounts are provided exclusively through participating flight schools and are created only for pre-authorized (whitelisted) email addresses.

Data processed includes:

  • Name
  • Email address
  • License or subscription status
  • Registration date

This data is used for:

  • Authentication and account management
  • License validation and access control
  • Providing Flight School Pro features

Account data is stored in Google Cloud Firestore (via Firebase). Processing is based on Art. 6(1)(b) GDPR (contract performance). Data is retained for the duration of the account and thereafter as required by law.

User data is typically provided by the respective flight school or by the user during account registration.

4.8 Voluntary User Communications

Users may contact the developer or submit feedback. If an email address is provided voluntarily:

  • It will be used solely to respond to the inquiry
  • It will not be used for marketing
  • It will not be shared with third parties

Website-Specific Processing

4.9 Website Hosting (Vercel)

The website is hosted by Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, USA. When you visit the website, Vercel automatically processes:

  • IP address
  • Date and time of the request
  • Requested URL and referrer
  • Browser type and operating system
  • Amount of data transferred

This data is processed to deliver the website and ensure its security. Server logs are retained briefly and then deleted automatically.

More information: vercel.com/legal/privacy-policy

4.10 Website Analytics (Vercel Web Analytics)

The website uses Vercel Web Analytics, a privacy-focused analytics service that does not use cookies and does not collect personally identifiable information.

Data collected is limited to:

  • Page views and navigation paths
  • Referrer information
  • Browser and operating system type
  • Device category (desktop, mobile, tablet)
  • Country of origin (derived from IP, not stored)

No individual visitors are tracked across sessions. IP addresses are not stored.

More information: vercel.com/docs/analytics/privacy-policy

4.11 Content Delivery and Fonts

The website loads fonts (Inter, Space Grotesk) from Google Fonts via Next.js font optimization, which self-hosts the font files at build time. No requests are made to Google servers when you visit the website.

Static assets (images, scripts) are served via Vercel’s edge network. No additional third-party CDNs are used.

4.12 Cookies and Local Storage

The website does not set cookies for tracking, advertising, or analytics purposes.

Strictly necessary technical data may be stored in your browser (e.g., timezone detection for currency display). This data remains on your device and is not transmitted to the developer.

5. Data Stored Locally on the Device

Certain information is stored exclusively on the user’s device to provide functionality, including:

  • Settings and preferences
  • Training progress and statistics
  • Usage counters
  • Saved scenarios or configurations

This data is not transmitted to or accessible by the developer. It may be included in device backups managed by the operating system.

6. User Accounts

The app does not require user registration for general use. Most users interact with the app anonymously without creating an account.

An exception applies to participants of the Flight School Pro program, who may create accounts using pre-authorized email addresses. Details on the data processed for these accounts are described in Section 4.7.

7. No Advertising or Marketing Tracking

The app:

  • Does not display third-party advertisements
  • Does not use advertising SDKs
  • Does not perform behavioral advertising
  • Does not sell personal data

8. Legal Bases for Processing (Art. 6 GDPR)

Processing is based on:

  • Legitimate interests (Art. 6(1)(f)) — improving app stability and functionality
  • Performance of a contract (Art. 6(1)(b)) — providing app services
  • Consent (Art. 6(1)(a)) where applicable
  • Legal obligations where required

9. Data Recipients and International Transfers

Data may be processed by service providers located outside the EEA, particularly in the United States. These providers state that they use appropriate safeguards, such as:

  • Standard Contractual Clauses (SCCs)
  • Additional security measures

10. Data Retention

Retention periods depend on the respective service provider:

  • Analytics and crash data are retained according to provider policies
  • Purchase records are retained as required for legal and accounting purposes
  • Email communications are retained only as long as necessary

11. Data Security

Appropriate technical and organizational measures are implemented to protect data against unauthorized access, loss, or misuse.

12. Children\u2019s Privacy

The app and website are not specifically directed at children under 16 years of age. They are intended primarily for pilots and aviation students. The developer does not knowingly collect personal data from children.

13. Automated Decision-Making

No automated decision-making or profiling within the meaning of Art. 22 GDPR takes place.

14. Your Rights Under GDPR

Users located in the EU/EEA have the right to:

  • Access personal data (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (“right to be forgotten”, Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Objection to processing (Art. 21 GDPR)
  • Withdraw consent at any time

Requests may be sent to contact@ifrsimulator.com.

Because the app does not maintain identifiable user profiles, fulfilling certain requests may be technically limited.

15. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state of your residence.

16. Changes to This Privacy Policy

This Privacy Policy may be updated periodically to reflect changes in the app or legal requirements.

17. Contact

For privacy-related questions: contact@ifrsimulator.com