Privacy Policy
At AXPA Systems S.L.U. we are committed to protecting the privacy and security of your personal data, in accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD).
1. Data Controller
AXPA Systems S.L.U. (NIF B26941039), registered at CR. Baños de Arteixo, 33, 15008, La Coruña, Spain. Data Protection Officer: Pablo Menéndez-Ponte Alonso — admin@axpa.app.
2. Purpose of Processing
We process the information you provide for the following purposes: (a) Management of your user account and platform access; (b) Provision of contracted services, including flight planning, fleet management, and operational viability analysis; (c) Billing and subscription management; (d) Service-related communications (updates, plan changes, security notifications); (e) Platform improvement through usage analysis, both by aggregate anonymous audience measurement and by product usage statistics linked to your account in pseudonymised form (section 11); (f) Sending marketing communications about AXPA Systems products, training and offers by email, phone or instant messaging (WhatsApp), only if you have given your express consent; (g) Organising group flights with other users and invitations between people who have already flown together (section 12).
3. Legal Basis
The legal basis for processing your data is: (a) Contract execution: necessary to provide the requested services; (b) Consent: given upon registration and acceptance of the Terms and Conditions. For marketing communications by phone or instant messaging we request specific, separate consent, which you may refuse without this preventing registration or use of the platform, and which you may withdraw at any time; (c) Legitimate interest: for service improvement, platform security and the product usage statistics described in section 11, and for the group flights described in section 12.
4. Data Processed
We collect the following data: registration data (first and last name, email, contact phone number, country of residence and encrypted password); a record of your consents (date of acceptance of the Terms and date of your decision on marketing communications); organization and membership data; fleet data (models, registrations, technical characteristics); flight operation data (geometries, trajectories, operational parameters); technical session data (IP address, browser type, necessary for service security). If you connect your flight controller to AXPA (live telemetry), we also process, during the flight, the aircraft's position, height, speed and status and the link quality, data that in practice amounts to the location of the person piloting it. If you take part in group flights, we process the place and date of each flight, who organises it and who joins, who is invited and, if you tell us, whether the flight took place. If you use friends, we process your handle, your friend link and who you are friends with or have pending requests with. If you upload your organisation’s operator registration certificate or registration receipt, we process that document and the operator details it contains (operator number, name or company name, tax ID, contact details, address and registration and expiry dates), which we use to complete any of your organisation’s details that are empty. If your organisation uses coordinations, we also process the coordination files (the operation and operator data each request contains), the documents you upload to them (operator registration certificate, EARO, agreements and receipts) and the PDF record of each assisted fill, which includes the name of the person who did it. If you register pilots, we process their profile (operator number, licence, radio call sign, flight hours and qualifications with their certificates).
5. Recipients
Your data may be communicated to: (a) Cloud infrastructure providers (Vercel, databases) for service hosting; (b) Payment and subscription management providers: Stripe for purchases made on the web, and RevenueCat for subscriptions bought through the app stores; (c) Our marketing agency, Makadu Ecommerce, S.L. (Spain), which manages on our behalf the CRM, marketing communications by email and WhatsApp and our advertising campaigns, and the CRM provider it uses (HighLevel, Inc., GoHighLevel, with servers in the United States). We send them your name, email, phone number, subscription plan, amount paid and the indicator of whether you have consented to marketing communications. Makadu acts as a data processor and HighLevel as a sub-processor, both solely on our instructions, and your phone number is only used for marketing purposes if you have consented to it. To send emails and WhatsApp messages they rely on their own providers, including Google and WhatsApp Business (Meta Platforms Ireland Limited). The international transfer to HighLevel relies on the EU-U.S. Data Privacy Framework and, failing that, on the Standard Contractual Clauses approved by the European Commission; (d) Competent authorities when legally required; (e) The distributor or reseller organisation (partner) that gave you a promotional code or a licence, at the moment you redeem it: we disclose the plan activated, the redemption date, the validity granted and your email domain, together with your organisation name ONLY where that organisation is a company. If you operate as an individual or sole trader, the partner does not receive your name: you are identified as “an individual customer”. Under no circumstances do we disclose your full email address or your phone number. Where the licence was delivered by a reseller that in turn received its inventory from a distributor, that distributor receives the same minimum information —the plan, the start and expiry dates and your organisation name only where it is a company— in order to manage its channel; that disclosure includes NO email address whatsoever, not even a partially masked one. That partner acts as an independent controller and solely for the purpose of managing its distribution channel (support, commission settlement and tracking of the codes it has handed out), and is contractually forbidden from using that data for its own commercial prospecting or disclosing it to third parties. (f) The mapping and aeronautical data providers from which your own browser requests tiles when drawing the map (such as OpenAIP, in Germany): for that technical reason they receive your IP address and the coordinates of the area you are viewing, but no data about your account, your organisation or your operations. (g) Anthropic Ireland, Limited, as data processor (which processes it in the United States through its parent company, Anthropic, PBC), only when you upload an operator registration certificate or registration receipt that our own reader does not recognise: we send it that document to read the operator number and the operator details it contains. Anthropic does not use it to train its models. This international transfer is covered by the Standard Contractual Clauses approved by the European Commission. We do not sell your data, nor do we share it with third parties for their own commercial prospecting. Live telemetry from connected controllers is received on our own server hosted by Hetzner Online GmbH (Germany), within the European Economic Area.
6. Data Retention
Your data will be retained as long as your user account remains active. After account cancellation, data will be kept blocked for the legally required period to address potential liabilities. Live telemetry is processed ephemerally: while the controller is connected, the server keeps only the last known position of each aircraft, visible only to members of your organization; on landing, the flight is stored as a regular flight log with the same retention as the rest of your data, and intermediate positions are not kept outside that record.
7. Data Subject Rights
You have the right to access, rectify, delete, port, restrict, and object to the processing of your personal data. You may exercise these rights by contacting our DPO at admin@axpa.app. You may also withdraw your consent to marketing communications at any time — from the 'Account Settings' section of the platform, from the user menu of the mobile app, via the unsubscribe link included in every marketing communication, or by writing to the DPO — without affecting the lawfulness of processing carried out beforehand. You may also file a complaint with the Spanish Data Protection Agency (www.aepd.es).
8. Security
We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or destruction. Passwords are stored encrypted, communications use secure protocols (HTTPS/TLS), and we apply robust session controls.
9. Account and Data Deletion
You can permanently delete your account and all associated data at any time from the 'Account Settings' section on the platform, using the automated deletion button. Alternatively, you can request the deletion of your account by sending an email to admin@axpa.app. Data will be permanently deleted, except for those that must be retained due to legal obligations.
10. Advertising Measurement and Campaign Attribution
If you consent to the advertising measurement purpose, we process usage data (device and advertising identifiers, IP address, sign-up and purchase events) in order to attribute those events to the campaign that produced them and assess its performance. The legal basis is your consent (Art. 6(1)(a) GDPR), which you may withdraw at any time from the "Privacy preferences" link in the footer or from the application settings. Recipients: Meta Platforms Ireland Limited, as joint controller for the data collected by its pixel; and AppsFlyer Ltd., as data processor for campaign attribution both on the website and within the mobile application, including linking an ad seen on the website to the subsequent app download, which in turn reports aggregated results to the contracted advertising platforms. These processing activities may involve international transfers to the United States, covered by the European Union–United States adequacy framework and, failing that, by standard contractual clauses. On iOS, attribution is performed through Apple's SKAdNetwork, which returns aggregated results and does not allow specific individuals to be identified. If you do not consent, the pixel is not loaded and the application's attribution system is not activated. Custom audiences on Meta: if you have agreed to receive our marketing communications, once a day your email and phone number are pseudonymised with a hash function (SHA-256) and sent to Meta Platforms Ireland Limited, which matches them against its own users as a data processor. We do this for two purposes: to avoid showing our acquisition ads to people who are already paying customers, and to create lookalike audiences, that is, people with a similar profile to whom we show our advertising. Meta does not receive your data in plain text and the audiences are managed in our own advertising account. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR) in targeting advertising efficiently and in not showing acquisition ads to our customers. You may object at any time by unsubscribing from marketing communications in your account settings or through the unsubscribe link in our emails: from that moment you are no longer included in these audiences.
11. Product Usage Statistics
We record, in aggregate, which platform features are used and how often — for example, how many operations are planned, which weather variables are consulted, or which feasibility analyses are run — associating those counts with a pseudonymised identifier of your account, with your organisation, and with your current plan. The purpose is purely statistical: to understand which parts of the product are useful, so we can decide what to improve and how to set prices and limits. We make no automated decisions about you, we build no individual profiles, our internal tools display aggregates only, and we neither share nor sell this information. The legal basis is our legitimate interest (Art. 6(1)(f) GDPR). You may object by writing to admin@axpa.app: we will then detach your counts from your account, and the statistics keep working without you. Detailed records are kept for 18 months; after that only an anonymous aggregate remains. Location associated with analyses and operations is grouped into broad zones with no link to any account, and outside our own team it is only used in a way that cannot refer to an individual customer.
12. Group Flights
If you organise or join a group flight, the other people who have joined see your first name and, if your account has one, your public photo. Your surname and email are not shown. Anyone who opens a flight link without joining only sees the approximate area; the exact spot is shown on joining. People who have been on a group flight with you in the last year can invite you directly to other flights, and the invitation reaches you as a notification on the platform and in the app. This processing is based on the legitimate interest of AXPA and of the people you have flown with in making it easy to fly together again (Art. 6(1)(f) GDPR). You can object at any time by turning off “Group flight: you're invited to fly” in your notification preferences; from then on you will not appear in anyone's invitation lists. After each flight we ask whether you flew. Answering is optional, and the answer is only used to order those lists and for usage statistics. This data is kept while your account is active; only flights from the last year are taken into account when suggesting who to invite. You can also set a handle (@) and share a friend link. Other people can send you a friend request by typing your exact handle or opening your link; a friendship only exists if both sides accept it, and your friends see your first name, public photo and handle, and can invite you to group flights. Nobody can find you by your email. You can remove your handle, decline requests or remove a friend at any time, and your friendships are deleted when you delete your account. This processing is based on providing the service you request (Art. 6(1)(b) GDPR). If you turn on “Share my activity with my friends” (off by default), your friends see your personal flights with the place name or locality (never the exact spot or company flights), your milestones and the group flights you organise, and can applaud them; people who flew with you on a group flight can also applaud you. You can send a friend a place from your personal organisation, and when organising a group flight from it you can notify your friends. The “Your year flying” summary is only published if you share its link, and shows your first name, public photo and aggregate figures, never places or companions. This processing is based on your consent, which you can withdraw by turning the option off (Art. 6(1)(a) GDPR), and on providing the service you request.
13. Mobile Coverage Contribution
If you turn on coverage contribution in the Android app, the phone records every few seconds, even when the app is closed or not in use, the mobile signal it receives (cell, strength and operator), the place where it is measured, the phone model, the barometric pressure, the GPS satellite status and a summary of nearby Wi-Fi networks, without their names or identifiers. No calls, messages, contacts or phone content are recorded. The purpose is to correct and improve the platform's mobile coverage map. The legal basis is your consent, which you can withdraw at any time by pausing or turning off the contribution from the notification or from Settings. Measurements are stored under a random installation identifier, without your name or your account, and AXPA does not keep the link between that identifier and your account. Only the number of hours contributed is associated with your account, to calculate free access to the full coverage layer; that figure is deleted together with the account. Measurements are deleted automatically after six months. They are used to calculate corrections to the coverage map, which are published without any information about who measured or when. Since the measurements are not linked to your account, AXPA cannot locate them to respond to an access or erasure request concerning them; in any event they are deleted when the six-month period ends.
14. AXPA Weather
AXPA Weather (the website weather.axpa.app and its Android and iOS apps) is used without an account. What it processes, and why: Favourite and recent places: stored only on your device. If you sign in with an AXPA account, your favourites are also saved to it so you can see them on other devices and in AXPA Planner. Location: only if you allow it. While you use the app, it is used to give you the weather where you are, and for that it is not sent to our servers or stored. If you turn on “Where you are” alerts, the app also sends your approximate position, rounded to one kilometre, when you open it and, with the app closed, when your phone moves a noticeable distance, so that we can alert you to rain or lightning reaching wherever you are. The “always” location permission is requested only for that option. Each position replaces the previous one, no history is kept, it stops being used after 3 days at most and it is deleted when you turn off “Where you are”. The purpose is to send you those alerts and the legal basis is your request. App verification: to give access to weather data without an account, the app proves it is genuine through its platform's service (Google Play Integrity on Android, Apple App Attest on iOS; Cloudflare Turnstile on the web). On iOS a public key linked to the installation is kept for 180 days, renewed with use. The legal basis is our legitimate interest in protecting the service against abuse. Rain and nearby lightning alerts: if you turn on “Alert me” for a place or “Where you are” alerts, we store your device's notification identifier (Firebase Cloud Messaging, by Google), the watched places with their coordinates, the alerts chosen for each one, the chosen lead time and intensity, the language and the time zone, under a random installation identifier and not linked to any account. The purpose is to send you those alerts and the legal basis is your request. They are deleted when you turn off your last alert or after 60 days without opening the app. Contributing coverage (Android only, optional and with an account): if you turn it on after the in-app notice, AXPA Weather measures the mobile signal as described in section 13, with the same purpose, legal basis and retention periods. What you contribute counts for your account: while you contribute, you see coverage across the whole map. Advertising: the free version of the apps shows Google AdMob ads. Before showing them you are asked for consent (and, on iOS, Apple's tracking permission) for personalised ads, which use the device's advertising identifier; without that consent ads are not personalised. You can change your choice in Settings, “Ad privacy”. The “No ads” purchase is handled by the app store: AXPA does not receive your payment details. Crash reports: if the app crashes, Firebase Crashlytics (Google) receives a technical report (the error, the device model and the system and app versions), without account data, so we can fix it. They are kept for 90 days. Usage statistics: to know how much and how AXPA Weather is used, the app counts on your device which features are used (for example, how many place pages are opened, which weather layers are viewed, or whether an alert is switched on or a place is shared) and sends us only those counts, under a random identifier of the installation, unconnected to any account and without your location; we do not store your IP address with them. After 14 days they become aggregate figures and the identifier is no longer kept. In addition, a few actions (opening the app, switching on an alert, sharing a place, viewing or buying AXPA Weather Plus) are recorded in Umami, an analytics tool that uses no cookies, together with the language, screen size, operating system and app version. The purpose is to improve the service and the legal basis is our legitimate interest; it is not used to profile you or for advertising. United States residents: in states with their own privacy law (California and the others that have one), showing you personalised ads may count as “sharing” personal data for advertising based on your activity. You can opt out in Settings, “Ad privacy”; from then on Google serves ads with restricted data processing. AXPA does not sell personal data for money. You can ask to access, correct or delete your data by writing to admin@axpa.app; we will reply within 45 days, and exercising these rights will not lead to any different treatment. Google acts in these services under its own terms and may process data outside the European Economic Area with the safeguards of the Standard Contractual Clauses. AXPA does not use any of the above to profile you or share it with third parties.
15. Coordinations and AXPA Permits
The coordinations module prepares, with your operation’s and organisation’s data, the requests and documents filed with authorities and air navigation service providers. AXPA does not file them on your behalf: you do. AXPA Permits is the browser extension that fills in those procedures for you on the official portals where they are filed. It only acts on those portals’ pages and on AXPA’s, and only when you use it: it reads from the portal’s form what it needs to know where to write, and writes into it the data of your file that AXPA sends it. It never submits the request or ticks the responsible declaration. In your browser it only stores the access key to your AXPA account (which you can revoke at any time from AXPA), the file you are filing and what happened with each field, without its values. What you answer in its panel is saved in your organisation in AXPA. If filling gets stuck because of a portal failure, the extension sends us a technical report —which steps failed and why— without your request data. When it finishes, the PDF record of the fill is saved in the operation’s documents. For portals that require it in every request, each pilot's profile can store their identity document (type and number). Only the pilot and whoever manages your organisation's staff can see it, and it is used only to fill in those requests. In a personal account the operator and the pilot are the same person, and AXPA uses a single number for both. The legal basis is the performance of the contract. This data is kept with the rest of your organisation’s data and deleted with it.
16. Nearby Drone Detection
If you turn on “Detect nearby drones” in the Android app, your phone listens, even when the app is closed or not in use, for the Remote ID that regulations require many drones to broadcast over Bluetooth and Wi-Fi, and sends AXPA the position, height, speed, heading, type, status and identification of each drone it picks up. The pilot’s position, the operator number, the free text and the authentication data broadcast by the drone are discarded on the phone itself and are neither sent nor stored. Your phone’s position is not sent. The purpose is to show drone traffic on the map to AXPA users in order to make operations safer. The legal basis for your participation is your consent, which you may withdraw at any time by pausing detection from the notification or from Settings. For the drone data, the basis is our legitimate interest in aviation safety (Art. 6(1)(f) GDPR): Remote ID is a public broadcast that regulations require precisely so that third parties can identify drones in flight. Other users see on the map, for a few seconds, the position, height, speed, type and an anonymous identifier of each drone, with no information about who picked it up. AXPA does not keep the serial number: it turns it into an anonymous code. To evaluate the service, the positions picked up are kept for 90 days with a pseudonymised fingerprint of your account; since only drones around you are picked up, they show roughly where you were. After that period they are deleted automatically, and you may ask for them to be deleted sooner by writing to admin@axpa.app.