Privacy Policy
Draft — not yet legally reviewed. This document describes how TrueCourse works, but a lawyer has not yet approved the wording. It is not final, and it will be finished before TrueCourse is published.
The short version
- We keep what we need to run your account, your course, your club's bookings and your chats.
- Your messages are deleted after 12 months.
- Nobody at TrueCourse reads your messages unless they are reported, or the law says we must. When we do, it is recorded.
- Your data is stored in the United Kingdom.
- We don't sell your data, and we don't show you adverts.
- You can see, correct or delete your data. Email support@zerobatics.com.
Who is responsible for your data
TrueCourse is run by Zerobatics Ltd, a company registered at Companies House with the number 15501115. We are responsible for your personal data (the "data controller"). Your account is handled under UK GDPR and Data Protection Act 2018. To ask about your data, email support@zerobatics.com.
Your account
We keep your email address and your password. The password is stored only as a scrambled code that can't be turned back into the password. We also keep the profile details you choose to give us: your name, a short biography, your region, your role, and the subjects you study.
Why: to run your account and show you the right course for your region.
Lawful basis: contract. We need this to give you the account you asked for.
Your date of birth
We ask for your date of birth when you create an account. TrueCourse is for people aged 13 and over, and we use your date of birth to check that you meet that age. If you are under 13, we don't create the account. Chat also uses it to decide which safety rules apply to you.
Your date of birth is not shown to other users or your instructors. If you ask a club or school to confirm it, they see it, and we record that they confirmed it. It can't be changed in the app once given. If it is wrong, email us to have it corrected.
Lawful basis: legitimate interests. Our interest is in keeping TrueCourse to people aged 13 and over, and in applying the right safety rules to young people. Both protect children.
Your course and your flights
We keep your study progress: the lessons you have finished and your quiz results, so you can carry on from any device.
Your aircraft, routes and flight plans stay on your phone. They are not sent to us.
When the app fetches aviation weather, it asks aviationweather.gov, a United States government service, directly. Like any website, that service can see your phone's internet address. We don't send it anything else about you.
Lawful basis for your progress: contract.
Clubs, schools and bookings
If you join a flying club or school, we keep your membership and your role there. If you run one, we keep its name, its website, and the details you give us to verify it. To check that a club owns its website, we send a code to an email address at that website.
We keep the bookings you make or are part of: the aircraft, the instructor, the times, whether the booking was accepted or cancelled, any reason given, and the lesson it was for. We keep the notices we send you about your bookings.
Who sees it: the owner and administrators of your club or school see your membership and its bookings. An instructor sees the bookings they are part of.
Lawful basis: contract. You asked us to put you in touch with your club and manage your bookings.
Instructor certificates
If you ask to be verified as a flight instructor, you upload a photograph of your instructor certificate. It shows your name, licence number, issuing authority and signature, so we treat it with particular care. We hold it on the lawful basis of contract: you have asked us to verify you, and we can't do that without seeing the certificate. You don't have to provide it. If you don't, you are simply not shown as verified.
The photograph is kept in private storage in the United Kingdom. Only a TrueCourse reviewer can open it. Not other users, not your school, and not you once it is uploaded.
The photograph is kept only until a reviewer has made a decision. An automatic check runs every 15 minutes and deletes every photograph that is no longer waiting for a decision and was uploaded more than an hour ago. In practice, it is deleted within 15 minutes of the decision, whether your certificate was accepted or not.
After that, we keep a record of the review: the outcome, who reviewed it and when, the certificate number, issuing authority and expiry date, and any notes you or the reviewer wrote. If a verified school vouches for you instead, no photograph is involved, and the record holds the expiry date the school entered. These records are kept for as long as your account exists.
Sharing your progress with an instructor
An instructor at your club or school can ask to be linked with you. Nothing is shared unless you accept. Once you have, they can see your progress on the course. You can end the link at any time, and the sharing stops.
Lawful basis: contract. Sharing your progress is something you choose to do in the app.
If you are under 18: your parent or guardian
Before you can chat, a club or school must check the details of one parent or guardian: their name, how they are related to you, and how to contact them. You also agree, on Age Check, that they may ask us for a copy of your messages.
Your data protection rights belong to you. If your parent or guardian asks for your messages, we check who they are, whether a court has said anything about it, and what you think, before we decide. We record every copy we give.
We delete your parent or guardian's details on your 18th birthday.
Lawful basis: legitimate interests. Our interest is in keeping young people safe while they chat.
Your messages
When you chat, we keep each message, who sent it, which chat it is in, and when it was sent. We don't keep your location, your device or your internet address with your messages. We also keep who is in each chat, who you have blocked, and when you agreed to the chat rules.
In a group chat, everyone in the group sees your name and your messages from when you joined. The club's owner or administrators who are in the group also see who has been invited. We keep each group invitation, who sent it and whether it was answered, and when each person joined and left a group.
Lawful basis: contract. We need this to deliver your messages.
Notifications
If you turn on notifications, we keep a code Apple gives your phone so that we can send them, and whether your copy of the app is a test version. We keep nothing else about your phone. We also keep which notifications you have turned on.
By default, a notification says only "New message", "You've been invited to a group" or "Booking update". It shows no names and no message text. If a club has confirmed you are an adult, you can choose to show who wrote and what they said, and what changed on a booking. In a chat with anyone under 18, or anyone whose age a club has not confirmed, a message is never shown in detail on anyone's lock screen.
Lawful basis: contract. We need this to send the notifications you turn on.
Keeping chat safe
To keep chat safe, we also:
- check every message for words that are not allowed, and for web addresses where they aren't allowed. This is automatic, and a message that is stopped is not saved;
- keep every report: who made it, why, any note, and a copy of the reported messages and the 10 messages either side of each, so it isn't lost if someone deletes their account;
- keep a record of what we did about each report, and of every time anyone at TrueCourse, or at a club, read a message.
If a chat that included someone treated as under 18 is reported, the owner and administrators of that club or school may read our copy of the report. Every time they do, it is recorded.
Lawful basis: legitimate interests. Our interest is in keeping the people who use TrueCourse, especially young people, safe, and in being able to show what we did and why. You can object, but we may carry on where we have strong reasons to, such as keeping a child safe.
When the law says we must
If we find child sexual abuse or exploitation on TrueCourse, the law says we must report it to the National Crime Agency, and keep certain information.
For everyone in the reported chat, a child included, we keep their name, email address and date of birth, the messages they sent or received in the two weeks before, in any chat, and their links to other accounts, including group invitations sent or received.
We also answer lawful requests from the police or the courts. We record every one.
Lawful basis: legal obligation. Because the law requires it, you can't ask us to delete this, or object to it, while the law says we must keep it.
Who we share your data with
- Supabase stores our database, handles sign-in, and keeps our files. It does this for us, in London.
- Resend sends some of our emails for us: the code we send to check a club's website, and alerts to our own team about new reports. Resend stores data in the United States.
- Apple delivers our notifications to your phone. A notification carries only what "Notifications" above describes.
- Your club or school, your instructor, and your parent or guardian see what the sections above say they see.
- The National Crime Agency, the police, a local council's safeguarding officer or a court, when the law requires it or a child is at risk.
We don't sell your data. We don't use it for advertising.
Data sent outside the United Kingdom
Your data is stored in the United Kingdom (eu-west-2). TrueCourse currently accepts accounts in the United Kingdom only.
Resend, which sends some of our emails, stores them in the United States. Resend says it protects data sent there with Standard Contractual Clauses.
How long we keep it
- Your account, profile, progress, memberships and bookings: for as long as your account exists.
- An instructor certificate photograph: until a reviewer has decided, as explained above.
- Your parent or guardian's details: until your 18th birthday.
- Messages: 12 months from when they were sent. A chat with no messages left is deleted once it is 12 months old.
- Group invitations: 12 months from when they were sent. A record of when someone left a group: 12 months from when they left.
- A report and its copy of the messages: 12 months after we have dealt with it. A report we are still dealing with is kept until we have.
- The code for sending notifications to your phone: until you sign out, until your phone has not opened TrueCourse for 90 days, or until you delete your account.
- Our records of what we did about reports, and of who read a message: 5 years. A record about an account that is still stopped from sending is kept for as long as it is.
If you delete your account, we delete your data, with these exceptions:
- Messages you sent stay in the other person's chat, no longer linked to your account, until they are deleted 12 months after they were sent. We keep them so that deleting an account can't remove what it said before anyone could report it.
- Bookings: one that has not started is cancelled, and the others on it are told. One that has started or already happened stays in the club's records, showing "Deleted user" instead of your name, because it is the club's record of who flew its aircraft and when.
- Reports and records are kept for the times above.
- If a report is open when you delete your account, or we may need to report something to the National Crime Agency, we keep a copy of what the law requires, as explained under "When the law says we must". If it is not reported, the copy is deleted seven days after the report is closed. If it is, the law requires us to keep it for one year, and the report's reference number for five years.
What you must give us
To have an account, you must give us your email address, a password and your date of birth. Everything else is up to you. If you are under 18, you can chat only once a club has checked your parent or guardian's details.
Decisions made automatically
Two things happen automatically, without a person deciding:
- the message check described in our Terms of Service stops some messages being sent;
- until a club confirms your date of birth, chat treats you as under 18.
If you think either has got something wrong for you, email support@zerobatics.com and a person will look at it.
We don't use your data to build up a picture of you, or to show you adverts.
Analytics and crash reports
The app does not collect usage analytics or crash reports.
Your rights
You have the right to:
- get a copy of your data;
- have wrong data corrected;
- have your data deleted;
- ask us to limit how we use it, or object to how we use it;
- get your data in a form you can take elsewhere.
Some of these rights have limits. Where the law says we must keep something, you can't have it deleted until the law allows. Where we use your data for our legitimate interests, you can object, and we will stop unless we have strong reasons not to, such as keeping a child safe.
You can also complain to the data protection regulator.
Contact and complaints
To ask about your data, or to use any of your rights, email support@zerobatics.com.
If you are unhappy with how we have handled your data, you can complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk.