Privacy Policy

1. Summary — No Data Collected

The Fly-Right App and the flyright.app website are designed not to collect personal information from users:

• No user accounts. The App does not require you to create an account, sign in, or provide your name, email address, phone number, or any other personal identifier.
• No analytics or trackers. We do not use Google Analytics, Facebook Pixel, advertising SDKs, third-party trackers, or any cross-app/cross-site tracking technology.
• No advertising. The App and the Site display no advertising. We do not sell, rent, or trade any information to advertisers, data brokers, or other third parties.
• No tracking cookies. The Site does not place tracking, advertising, or analytics cookies on your device.
• Your content stays on your device. All inspection checklists, emissions calculations, SAF logs, photos, notes, documents stored in the Customizable Appendix, and PDF reports remain on your iPhone or iPad. Sharing requires an explicit action by you.

2. Scope

This Privacy Policy applies to the Fly-Right App and to the flyright.app website. It does not apply to third-party services we link to from the Site (such as the Apple App Store) or to email correspondence you choose to send us, which is governed by your email provider's terms.

3. What We Do Not Collect

Fly-Right does not collect, request, store, transmit, or process any of the following:

• Names, email addresses, phone numbers, or postal addresses
• Government-issued ID numbers, pilot certificate numbers, or medical information
• Aircraft tail numbers (you may type them into the App, but they remain on your device)
• Inspection content, photos, notes, or documents you create in the App
• Precise or coarse geolocation data
• Contacts, calendar, photos library (beyond a single photo you choose to attach), microphone, or camera roll
• Browsing history, search history, or web activity
• Health, fitness, biometric, or sensor data
• Apple's Identifier for Advertisers (IDFA) — the App does not request or use it
• Device sensor data (accelerometer, gyroscope, etc.)
• Payment-card numbers, bank account numbers, or other financial information

4. What Stays on Your Device

The App stores the following information locally on your iPhone or iPad. None of this information is transmitted to Fly-Right's servers (we do not operate user-data servers):

SAFA Inspection Checklist app:

• Tail-number profiles you create
• SAFA inspection checklist responses, notes, and photos
• Documents you upload to the Customizable Appendix (Letters of Authorization, Operational Specifications, insurance certificates, etc.)
• PDF inspection reports the App generates
• App settings and preferences

Aviation Carbon Emissions Calculator app:

• Aircraft and tail-number profiles you create
• Flight legs you log (date, route, block fuel or distance, aircraft type)
• Sustainable Aviation Fuel (SAF) uplift records (blend percentage, certifying body, batch ID, feedstock)
• PDF and CSV emissions reports the App generates
• App settings and preferences

All information from the App is encrypted at rest using iOS Data Protection. If you enable iCloud Backup on your device, Apple will include the App's local data in your encrypted iCloud backup; that backup is governed by Apple's Privacy Policy, not ours.

5. Apple App Store & Subscription Processing

The App are distributed exclusively through the Apple App Store. The App is sold as a separate, independent auto-renewing annual subscription at $149.99 USD per year. Subscriptions to the App are processed by Apple using Apple's StoreKit framework. Apple — not Fly-Right — handles all aspects of payment, billing, refunds, receipts, and renewal notifications. Fly-Right does not see, store, or have access to your name, billing address, payment-card number, Apple ID, or other Apple account information.

Apple provides Fly-Right with anonymized aggregate sales reports (e.g., total number of subscribers in a given country during a given month) so that we can pay applicable taxes and report royalties. We do not receive, and cannot derive, individual user identities from these reports.

Apple's collection and use of your information when you purchase or use the App is described in Apple's Privacy Policy and Apple Media Services Terms and Conditions.

6. Subscription Management & Cancellation

All in-app subscription renewals are maintained through the Apple App Store. The App is sold as an independent auto-renewing annual subscription at $149.99 USD per year. Apple — not Fly-RightLLC — processes every payment, manages every renewal, issues every receipt, and handles every refund through the StoreKit framework and the Apple ID associated with the device.

The following auto-renewal terms are required by the Apple Developer Program License Agreement (Schedule 2) and Apple App Review Guideline 3.1.2(a). These terms apply to the single Fly-Right App subscription:

• Title of publication / app and length of subscription: Fly-Right (SAFA Inspection Checklist with built-in Aviation Carbon Emissions Calculator) — 1-year subscription.
• Price of subscription: $149.99 USD per year (or local-currency equivalent as displayed on the Apple App Store at the time of purchase).
• Payment will be charged to your Apple ID account at confirmation of purchase.
• Your subscription automatically renews unless auto-renew is turned off at least 24 hours before the end of the current period.
• Your account will be charged for renewal within 24 hours prior to the end of the current period at the price disclosed above. Apple displays the renewal price to you before the renewal occurs.
• You can manage your subscription and turn off auto-renewal by going to your Apple ID Account Settings after purchase: Settings → [your name] → Subscriptions → [SAFA Inspection Checklist].
• No cancellation of the current subscription is allowed during an active subscription period. Cancellation takes effect at the end of the current billing period; no partial-period refunds are issued by Fly-RightLLC except where required by law. Apple may issue a refund at its discretion in accordance with its policies.
• Privacy Policy: https://flyright.app/privacy.html
• Terms of Use (EULA): https://flyright.app/terms.html

Refund and billing inquiries (receipts, chargebacks, refund requests, family-sharing issues) are handled by Apple and not by Fly-RightLLC. Contact Apple Support at support.apple.com/billing or request a refund directly at reportaproblem.apple.com.

Family Sharing. Both subscriptions are eligible for Apple's Family Sharing where enabled. When you turn on Family Sharing, Apple makes the subscription available to other members of your family group. Fly-RightLLC does not see who you share with or any information about your family group.

Restore Purchases. If you reinstall an App or switch to a new iOS device, tap the "Restore Purchases" button on the App's main settings screen and StoreKit will verify your subscription with Apple. Fly-RightLLC does not need any login or account information to restore your subscription; Apple handles the entitlement check.

7. Account Creation & Deletion (Apple App Review Guideline 5.1.1(v))

The App does not offer in-app account creation, registration, or sign-in. The App does not store user-identifying credentials, profile data, or any other server-side account record. There is no account associated with you on Fly-RightLLC's systems.

Because we do not create user accounts, the in-app account-deletion mechanism required by Apple App Review Guideline 5.1.1(v) is not applicable. If you wish to permanently remove all data created in the App, simply delete the App from your iPhone or iPad — all locally stored content (inspection profiles, photos, notes, Appendix documents, flight legs, SAF records, emissions reports) is permanently removed from your device. Apple may retain a record of the App purchase under your Apple ID; that record is governed by Apple's Privacy Policy.

If for any reason you believe Fly-RightLLC has retained personal information about you, you may request its deletion by emailing inquiry@flyrightconsulting.com. We will respond within 30 days.

8. In-App Permission Requests

The App are designed to request the minimum number of permissions. The following iOS permission prompts may appear during normal use:

• Camera — requested only when you tap "Attach Photo" inside the SAFA Inspection Checklist app to photograph a finding, placard, or document. The photo is saved locally to the App. No photo is transmitted to Fly-RightLLC.
• Photo Library — requested only when you tap "Choose from Photos" to attach an existing photo. We use the limited-access photo picker so we only see the photo you select.
• Files — requested only when you import a PDF document into the Customizable Appendix (such as a Letter of Authorization or insurance certificate). The file is saved locally to the App. No file is transmitted to Fly-RightLLC.

The App does not request Location, Contacts, Calendar, Microphone, Bluetooth, Motion, Speech Recognition, HealthKit, HomeKit, or any other sensitive permission. The App does not display the App Tracking Transparency prompt because the App does not engage in tracking.

9. Push Notifications

The App does not send push notifications. The App does not request push-notification authorization from iOS. We have no plan to add push notifications. If this changes in the future, we will update this Privacy Policy and obtain your iOS-level consent before sending any notification.

10. Privacy Nutrition Label Correspondence

Apple requires every iOS app to declare its data-collection practices in App Store Connect, which Apple then displays on the App Store as a "Privacy Nutrition Label." This Privacy Policy is consistent with the Privacy Nutrition Label Fly-RightLLC has filed for the App. Specifically:

• Data Used to Track You: None.
• Data Linked to You: None.
• Data Not Linked to You: Optional Apple-mediated crash diagnostics (only if you have enabled "Share With App Developers" in iOS Settings).

Privacy Nutrition Label categories mapped against our practices:

• Contact Info (name, email, phone, address) — not collected
• Health & Fitness — not collected
• Financial Info — processed by Apple via StoreKit; Fly-RightLLC does not see your payment details
• Location (precise or coarse) — not collected
• Sensitive Info — not collected
• Contacts — not collected
• User Content (emails, messages, photos, audio, gameplay, customer support, other user content) — stored locally on your device only; not transmitted to Fly-RightLLC
• Browsing History — not collected
• Search History — not collected
• Identifiers (User ID, Device ID) — not collected; IDFA is not used
• Purchases — processed by Apple; Fly-RightLLC receives only anonymized aggregate sales reports
• Usage Data (product interaction, advertising data, other usage data) — not collected; no analytics
• Diagnostics (crash, performance, other diagnostic data) — only if you opt in via iOS Settings → Privacy & Security → Analytics & Improvements → Share With App Developers; anonymized by Apple
• Other Data — not collected

If you observe any discrepancy between Apple's Privacy Nutrition Label and this Privacy Policy, please report it to inquiry@flyrightconsulting.com and we will investigate and correct promptly.

11. Optional Apple Crash & Performance Reports

If you have enabled "Share With App Developers" under Settings → Privacy & Security → Analytics & Improvements on your iPhone or iPad, Apple may send Fly-Right anonymized crash logs and performance metrics for the App. These reports do not contain your name, Apple ID, IDFA, or any personally identifiable information; they describe what the App was doing at the moment of a crash so we can fix bugs.

You can disable this at any time on your device. Disabling it will not affect your use of the App.

12. Website Hosting & Server Logs

The flyright.app website is a static website hosted by a commercial web-hosting provider. Like virtually all web servers on the internet, the hosting provider automatically records technical request logs that may include your IP address, browser type, the page requested, and the time of the request. These logs are used solely for security, abuse-prevention, and operational troubleshooting by the hosting provider. Fly-Right does not maintain a copy of these logs, does not link IP addresses to individuals, and does not use them for analytics or marketing.

The Site does not contain forms, login fields, or any other input that would transmit information from you to us, with the single exception of the email links labeled inquiry@flyrightconsulting.com. Clicking those links opens your own email program — they do not send anything from your browser to our servers.

13. Cookies & Similar Technologies

The Site does not place tracking cookies, advertising cookies, analytics cookies, fingerprinting scripts, or local-storage trackers. Your browser may cache static files (HTML, CSS, images) for performance, which is standard internet behavior and does not identify you.

The App does not use cookies. The App does not use Apple's Identifier for Advertisers (IDFA), Apple's Identifier for Vendors (IDFV) for tracking purposes, or any device fingerprinting.

14. Analytics, Advertising & Tracking

Fly-Right does not use Google Analytics, Mixpanel, Amplitude, Firebase Analytics, AppsFlyer, Adjust, Branch, Facebook Pixel, TikTok Pixel, or any other analytics or attribution service. The App and the Site contain no advertising and no third-party advertising SDKs.

We do not engage in cross-app tracking, cross-site tracking, behavioral advertising, or "sharing" of data for advertising purposes as those terms are defined under the CCPA/CPRA, the GDPR, or Apple's App Tracking Transparency framework.

15. Children's Privacy

The App and the Site are professional tools intended for use by adult business aviation pilots, flight-department staff, sustainability officers, and other aviation professionals. They are not directed to children under the age of 13 (or under 16 in the European Economic Area), and we do not knowingly collect any information from children. The App does not require an account, does not collect personal information from any user, and does not contain user-to-user communication or social features.

Because we do not collect personal information from any user, we do not collect personal information from children. If you believe a child has somehow provided personal information to us, please contact inquiry@flyrightconsulting.com and we will respond promptly.

16. Sharing of Information

Because we do not collect personal information, we do not share personal information with third parties. The narrow exceptions are:

• Apple Inc. handles all subscription purchases for the App as the sole payment processor. We have no choice in this — it is required by Apple's App Store policies.
• Our web-hosting provider processes server requests when you visit flyright.app, as described above.
• Legal compliance. If we ever receive a valid legal process (subpoena, court order, etc.) that compels us to disclose information, we will only disclose information actually in our possession; because we do not collect data, we typically have nothing to disclose. We will inform affected individuals where lawfully permitted.

We do not sell, rent, lease, or trade information to advertisers, data brokers, marketing firms, or any other third party.

17. "Sale" or "Sharing" of Personal Information

Fly-Right does not sell personal information for monetary or other valuable consideration, and does not share personal information for cross-context behavioral advertising, as those terms are defined under the CCPA, CPRA, VCDPA, CPA, and other state privacy laws. We have not done so in the preceding twelve (12) months and have no plans to do so. We have not knowingly sold or shared the personal information of consumers under sixteen (16) years of age.

18. Data Retention

Because we do not collect personal information, we have no retention period to disclose. Information you create in the App is retained on your device until you delete it. Apple's anonymized aggregate sales reports for the App are retained by Fly-Right for the period required by tax and accounting law (typically seven years).

19. Security

We use reasonable technical and organizational measures to protect the limited information that flows through our systems:

• The Site is served over HTTPS (TLS 1.2 or higher).
• The App store local data using iOS Data Protection (AES-256 at rest).
• Apple App Store subscription transactions are processed using Apple's secure StoreKit framework; receipts are validated using Apple-provided cryptographic signatures.
• We do not operate user-data servers, which materially reduces the surface area for security incidents.

No system is completely secure. If a security incident occurs that affects information we hold, we will notify affected individuals and applicable regulators as required by law.

20. International Users

Fly-RightLLC is based in the United States. The flyright.app website is hosted in the United States. The App are distributed worldwide via the Apple App Store. Because we do not collect personal information, no cross-border transfer of personal information occurs as a result of using the App or the Site.

21. Your Privacy Rights

Even though we do not collect personal information, applicable privacy laws give you certain rights, which we honor:

• Right to know / right of access — to confirm whether we hold personal information about you. (We will confirm that we do not.)
• Right to deletion — to request deletion of personal information. (Generally not applicable since we do not hold any.)
• Right to correction — to correct inaccurate information. (Generally not applicable.)
• Right to portability — to receive a copy of personal information in a portable format. (Generally not applicable.)
• Right to opt out of sale or sharing. (We do not sell or share, but you may submit a request anyway.)
• Right to non-discrimination — we will not retaliate against you for exercising any privacy right.
• Right to lodge a complaint with your local data-protection authority.

To exercise any of these rights, email inquiry@flyrightconsulting.com with the subject line "Privacy Rights Request" and a description of what you'd like us to do. We will respond within forty-five (45) days, or sooner where required by applicable law.

22. Notice to California Residents

Under the CCPA/CPRA, California residents have the rights described in Section 16 above. The categories of personal information that the CCPA defines, and our practices regarding each:

• Identifiers — not collected
• Personal records (Cal. Civ. Code §1798.80) — not collected
• Protected classifications — not collected
• Commercial information — not collected by Fly-Right; subscription transactions are processed by Apple
• Internet or network activity — not collected
• Geolocation — not collected
• Sensory information — not collected
• Professional or employment information — not collected
• Education information — not collected
• Inferences — not drawn
• Sensitive personal information (CPRA category) — not collected

Shine the Light: California Civil Code §1798.83 permits California residents to request information regarding our disclosure of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing.

23. Notice to EEA, UK, and Swiss Residents

For users in the European Economic Area, the United Kingdom, or Switzerland: because Fly-Right does not collect personal information, we are typically not acting as a "data controller" or "processor" under the GDPR or UK GDPR with respect to users of the App or the Site. Should this change in the future, we will update this Policy and provide the legal-basis disclosures required under Article 6 GDPR.

You have the right to lodge a complaint with your local supervisory authority. EEA: see https://edpb.europa.eu. UK: the Information Commissioner's Office (ICO) at https://ico.org.uk. Switzerland: the Federal Data Protection and Information Commissioner (FDPIC).

24. Apple App Tracking Transparency (ATT)

The App does not perform tracking as defined by Apple's App Tracking Transparency framework. The App does not link user or device data collected from the App with user or device data collected from other companies' apps, websites, or offline properties for targeted advertising or measurement purposes, and the App does not share user or device data with data brokers. As a result, the App does not display the App Tracking Transparency permission prompt.

25. Third-Party Links

The Site contains links to third-party websites (including Apple's App Store and links to Apple's privacy resources). Their privacy practices are governed by their own policies, not ours.

26. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last updated" and "Effective" dates at the top reflect the most recent revision. Material changes will be communicated through the Site or, where feasible, within the App. Your continued use of the App or the Site after the changes take effect constitutes acceptance of the revised Policy.

27. Contact Us

All privacy questions, requests, complaints, and rights-related correspondence should be directed to:

Fly-RightLLC
Attn: Privacy
Email: inquiry@flyrightconsulting.com

We respond to every privacy inquiry. There is no separate phone line, postal address, or web form for privacy matters — please email us directly.