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Privacy Policy

Version 2026-10-20-flugbuch · As of 20 October 2026

This is a convenience translation. The German version („Datenschutzerklärung") is the legally binding one; in case of any discrepancy the German wording prevails.

This Privacy Policy describes how Diebold IT GmbH, as the operator of Skyminator, handles your personal data. We comply with the General Data Protection Regulation (GDPR). For questions you can reach us at any time at datenschutz (at) skyminator (dot) com.

1. Controller

The controller within the meaning of the GDPR is:
Diebold IT GmbH
Donaustraße 6, 88239 Wangen im Allgäu, Deutschland
E-mail: datenschutz (at) skyminator (dot) com

No data protection officer under Art. 37 GDPR has been appointed; the controller can be reached directly for all data-protection matters. All servers (application, database, AI infrastructure, archive and mail server) run on our own hardware in Germany. No external hosting provider is involved.

2. Scope of data use and service status

Skyminator is currently free of charge; a future pricing model will be announced at least four weeks in advance. We deliberately process extensive data about your use: flights, sensors and telemetry. We use this data to develop the application, the algorithms and the AI models further. By registering you agree that we may process, store and exploit this data within the meaning of section 4. Your rights under the GDPR (section 7) remain unaffected. If you do not want this data use, please do not use Skyminator. Skyminator is under continuous development; features, availability and data formats may change.

3. Data collected and purposes

We keep the complete record of processing activities under Art. 30 GDPR internally and make it available for inspection on request.

3.1 Account and master data

The account comprises name, e-mail address, password (bcrypt hash only), preferred language and timestamps of registration and consents. Since 14 October 2026 a telephone number with country code is also mandatory at registration; we use it only to reach you on operational and safety matters concerning your account, never for advertising. You confirm your e-mail address with a code or link that we send you by e-mail; we store the code only as a hash and delete it upon confirmation, at the latest after seven days (Art. 6(1)(b) GDPR). In your profile you may store address, telephone numbers and date of birth; they serve identification in the logbook and proof of training under AMC1 FCL.050. If you upload licences, medical certificates or instructor ratings, or import them from Vereinsflieger, we store type, number, authority, expiry date and the document itself in order to remind you before expiry and to attach the licence status to signatures. If you connect Vereinsflieger, we store your Vereinsflieger member number, your roles there (student pilot, instructor) and your Vereinsflieger credentials in encrypted form (Art. 6(1)(b) GDPR).

3.2 Logbook, signatures and proofs (Art. 6(1)(b) GDPR)

The logbook comprises date, departure and destination, off-block and on-block time, flight time, block time, landings, launch type, pilot function (PIC, dual, FI, FE, SPIC, PICUS), companion and remarks; for the aircraft registration, type, class and propulsion. Automatically detected flights are drafts for two days and are then committed to the hash chain. Every change creates a new version; we keep versions and the hash chain as proof of integrity.

Signatures (your own and those of instructors or examiners) are stored with ECDSA signature, timestamp, device metadata and the licence status of the signing person valid at the time of signing; this licence status is part of the proof and visible to the person whose entry was signed. If you request a signature, the requested person sees the entry. If you grant logbook access, an instructor or club administrator can view your logbook as long as you share a club. Experience proofs are shared with the confirming instructors.

The obligation to keep your logbook (at least five years after the last entry, AMC1 FCL.050, § 120 LuftPersV) lies with you as the pilot. We keep the logbook as long as your account exists. If you delete your account, we delete your logbook completely with it: entries, drafts, versions, the signatures on your entries, your hash chain and audit chain, brought-forward totals, FSTD times, experience proofs and logbook access grants. Download it beforehand as PDF or JSON, the deletion request offers both. Signatures you made as an instructor in other pilots' logbooks and your public keys remain, because they are part of those persons' records.

3.3 Operational flight data (Art. 6(1)(b) GDPR)

During active flights we record GPS positions at 1 to 5 Hz (latitude, longitude, altitude, speed, track, time) for flight detection, map and airspace display, warnings, polar calculation and winch and aerotow detection. Acceleration, gyroscope and vibration data serve engine-run and seat detection; air pressure serves QNH and altitude. If hardware is connected, pitot, vario and winch telemetry are added. With the switch "Share the whole flight" you decide whether the complete track is transmitted over mobile data during the flight or later on Wi-Fi. For session management we store API tokens, session data and temporary share links.

3.3.1 Background location (Android ACCESS_BACKGROUND_LOCATION, iOS "Always")

For reliable flight detection Skyminator needs the location even when the app is not in the foreground or the screen is off; otherwise take-off, landing and route data would be lost as soon as the device is in your pocket. Collected are latitude, longitude, altitude, ground speed, track and timestamp. Purpose: exclusively flight detection, logbook, map and airspace display and the sharing features described in 3.4 if you switch them on. No advertising, no marketing, no location profiling outside flight contexts. Raw data stays on the device for at most 7 days; condensed flight data permanently in the logbook. You can switch location off at any time under More → Flight & sensors → Location or revoke the permission in the system; the app then works with restrictions (manual logbook keeping). During recording a persistent notification ("Skyminator is recording your flight") shows the use of location.

3.3.2 Microphone and cockpit audio (Art. 6(1)(b) GDPR)

Skyminator uses the microphone for engine-run detection (engine running time and block time). Detection runs locally on your device; spoken content is not analysed. During a flight the app records the cockpit audio at 16 kHz. This recording may contain conversations on board and radio traffic audible in the cockpit. It is transmitted to our server only over Wi-Fi, regardless of the switch "Share the whole flight". Purpose: improving and checking engine detection and investigating errors and incidents (forensics). Spoken content is neither analysed nor turned into text. On the server we delete the recording 90 days after the upload; the flight itself is kept. The app clears recordings on the device after 14 days at the latest. You can withdraw microphone access at any time in the system settings (engine-run detection then no longer works and no recording is made).

Legacy data of the former radio transcription. Until 13 October 2026 Skyminator offered a radio transcription feature; it has been switched off. Audio snippets and transcripts from that time may be stored for your account. They are no longer processed, are kept until your account is deleted and are fully deleted earlier upon your request (section 7). Technical logs of that processing are deleted after 30 days.

3.4 Live sharing: traffic, winch, cockpit (Art. 6(1)(a) and (b) GDPR)

Traffic display. If "Show other traffic" is on, you see aircraft from the Open Glider Network (OGN) and other Skyminator users within the set radius; conversely your current position with registration is visible to other Skyminator users nearby while you fly. OGN data is public data of the OGN network; we do not send data to OGN. Winch. In winch-operator mode the winch operator's device receives the speed and altitude of the launching aircraft; conversely the device in the cockpit sends this telemetry to all winch-operator devices at the same airfield. The channel is bound to the airfield. Cockpit and seat detection. Several devices on board are assigned to the same flight based on their motion data; the assignment can be confirmed or changed.

3.5 Club features (Art. 6(1)(b) and (f) GDPR)

Within a club, active members see the club's flight list (registration, pilot, companion, times). Fees and remarks from Vereinsflieger are visible only to the respective pilot, club administrators and the operator. For reconciliation with Vereinsflieger we store copies of the flight data kept there, including names; when an account is deleted they are cleansed of that name. Depending on the club's configuration, a member's device (or a device operated by the club) reads and writes the club logbook at Vereinsflieger on behalf of the club; for this we count the number of requests, not their content. Club administrators manage members, roles, aircraft, access rules and reservations; workshop managers and holders see aircraft logbook, maintenance and weighing data; heads of training approve the signing keys of instructors. The operator receives an operational notice for new clubs, accounts and memberships.

3.6 Diagnostic and error logs (Art. 6(1)(f) GDPR)

For stability and error analysis we collect client-side error logs, crash reports, the app version and device and operating-system metadata. On request or when reporting errors you transmit a log bundle from your device to us. Server-side request logs (IP, user agent, path) are processed to prevent abuse and for stability analysis. We anonymise where possible; in targeted error analyses a personal reference may remain.

3.7 ATIS retrieval (Art. 6(1)(b) GDPR)

At your request our server calls the public, freely accessible ATIS telephone number of an aerodrome, records the announcement and transcribes it with our own models. The telephone connection is established by Twilio Inc. (USA) as processor (Art. 28 GDPR, standard contractual clauses under Art. 46(2)(c) GDPR). Twilio receives only the called number and the recording of the announcement; the announcement itself contains no data about you. Per retrieval we store who triggered it, when and for which aerodrome, as well as recording and transcript as weather and aerodrome information for all users.

3.8 Route planning, weather, maps and country advice

Route briefing, altitudes, detours, fuel stops, flyability, weather, airspace, NOTAM, obstacles, aerodromes and the advice on entry and microlight rules are computed by our server from data of openAIP, OpenFlightMaps, DFS (AIP), the Georgian eAIP, the German Weather Service (ICON-D2, CC BY 4.0), open-meteo, aviationweather.gov, autorouter, notaminfo, airnav.ge, OurAirports, GeoNames and the Mode-S register. The server transmits only coordinates of grid cells or aerodromes to these sources, no data about you. Saved routes, flight plans and your personal performance values per aircraft are stored in your account. Fuel reports ("guests can refuel here") are stored with your account but shown to others only as a majority verdict. Map tiles are loaded by the app directly from the servers of the OpenStreetMap Foundation, which thereby receives your IP address and the displayed map area. Regions downloaded offline avoid this.

3.9 Push notifications, WeGlide, web

Push notifications are delivered by Apple (iOS) and Google (Android); only the device token is transmitted (standard contractual clauses under Art. 46(2)(c) GDPR). On Android the app also uses Google Play services for location. If you enable WeGlide, we transmit the flights you select to WeGlide UG. The web interface uses a technically necessary session cookie and stores your language choice; we set no tracking or advertising cookies.

3.10 Documents: licences, medical, identity document and aircraft papers (Art. 6(1)(b) GDPR, medical Art. 9(2)(a) GDPR)

You can upload certificates as a scan, photo or PDF: pilot licence, medical certificate, radio certificate, language proficiency, security background check (ZÜP), identity document, Part-66 licence and other documents. The operator, the club board and workshop manager of the operating club and the assigned CAMO can upload aircraft papers (for example certificate of airworthiness, certificate of registration, proof of insurance, weighing report). The files are stored only on our own servers in Germany, without public links, and can only be retrieved after signing in.

Reading. On request our server reads the details (number, issuing body, date of issue and expiry, class) using text recognition and an AI model on our own hardware. No data goes to third parties. The result is only a suggestion: it counts only after you have checked and confirmed it. We do not store the recognised text. Confirmed details of licences, medical, radio certificate, language proficiency and Part-66 are kept with your licences (section 3.2). Confirmed data from aircraft papers is taken over into the aircraft master data and the change is recorded in the aircraft logbook.

Who sees what. Your personal documents, including the identity document and the medical, are visible to you and, read-only, to the board of every club in which you are an active member. For support, super admins of the operator can read them; every such access is logged. Aircraft papers are visible to the operator, the owner, the board and workshop manager of the operating club, the assigned CAMO and, read-only, the active members of the operating club (for a private aircraft, members of a club in which the operator is also a member). The app keeps the list and the aircraft papers encrypted on the device so that they are available without a network. It downloads aircraft papers in advance only on Wi-Fi; on mobile data only when you open a document.

Medical. A medical certificate contains information about your health (class of fitness, limitations), i.e. special categories of personal data under Art. 9 GDPR. Whether you upload it is your decision; you can delete it at any time. The same rules on storage, reading and visibility as above apply.

Legal basis for the medical: your explicit consent (Art. 9(2)(a) GDPR). Before you upload a medical for the first time, the app and the web ask you explicitly whether Skyminator may store it, read it with the AI model on its own hardware and show it to you, the board of your clubs and the super admins. Without this consent we do not accept a medical. We store the time and the version of the consent text. You can withdraw the consent at any time under "My documents" (Art. 7(3) GDPR); the withdrawal takes effect for the future, and a new medical is only accepted after renewed consent. Withdrawal does not delete medicals already stored; you can delete them there yourself. Medicals stored before 14 October 2026 without separate consent remain until you delete them; we ask before the next upload.

Reminders and deletion. Before confirmed documents expire we remind you in the app and additionally by e-mail 30 days before and on the day of expiry; for aircraft papers the operator, board and workshop manager receive the reminder. A deleted document is removed together with its file. If you delete your account, we delete your personal documents and scans completely. Aircraft papers remain in the aircraft's records without any reference to you.

4. Data use

We use Skyminator to develop further the algorithms, the AI models and the operational heuristics: flight, seat, winch and aerotow detection, polars, weather matching. For this we use all data named in section 3, anonymised and aggregated and, where necessary, with personal reference for targeted error analysis and model improvement. By registering you grant Diebold IT GmbH a licence, unlimited in time and territory, transferable, sublicensable and free of charge, to all data you submit, insofar as necessary for the purposes in 4.1 to 4.3. This licence survives termination of the account insofar as the data has been anonymised or statutory retention obligations exist.

4.1 Anonymised and aggregated data

From flight, sensor, telemetry and weather data we create anonymised data products: statistical analyses, weather patterns, training metrics and AI model datasets. After anonymisation they can no longer be attributed to a person (Recital 26 GDPR). We exploit them commercially at our discretion, license them to third parties and publish them. The preceding anonymisation is based on Art. 6(1)(f) GDPR (product development, research, flight safety, economic viability).

4.2 Registration- and sensor-related data

Polars, sink rates, engine data, operating hours and similar flight performance are attributed to the aircraft, not to the flying person. We store them permanently, use them for development and exploit them commercially, for example as type statistics and comparison values between aircraft.

4.3 Use with personal reference

We use personal flight and sensor data to train and fine-tune our AI models, to improve flight, seat, winch and aerotow detection on real sessions and for targeted error analyses. The legal basis is your consent given on registration (Art. 6(1)(a) GDPR), which you may withdraw at any time with effect for the future (section 8). Because the data use is at the core of our offering, a withdrawal may lead to termination of your account. Your personal data is not passed to third parties for commercial purposes.

5. Recipients

We operate application, database, AI infrastructure, archive and mail server ourselves on our own hardware in Germany; no hosting provider or other processor is involved for this. Beyond that, data is received only by: Vereinsflieger (Breitenbach und Otero GbR) if you or your club enable synchronisation (Art. 6(1)(b) GDPR); WeGlide UG if you publish individual flights; Twilio Inc. (USA) for the telephone connection of the ATIS retrieval; Apple Inc. and Google LLC for push notifications and Google Play services on Android; the OpenStreetMap Foundation for map tiles your app retrieves directly; other Skyminator users and members of your club to the extent described in sections 3.2, 3.4, 3.5 and 3.10. Third-country transfers to Twilio, Apple and Google are secured by standard contractual clauses under Art. 46(2)(c) GDPR.

6. Retention and archiving

Principle: we do not delete flight recordings, polars or weather and sensor data but archive them permanently. Personal attributes such as name, address or e-mail address are anonymised after the statutory period; the technical records remain.

Data categoryRetentionLegal basis
Own logbook (FCL and microlight)Until the account is deleted, then deleted completely. Retention under AMC1 FCL.050 and § 120 LuftPersV lies with the pilot.Art. 6(1)(b) GDPR
Audit trail (hash chain, signatures) of the own logbookTogether with the logbookArt. 6(1)(b) GDPR
Signatures as instructor in other pilots' logbooksAs long as the other person's logbook existsArt. 6(1)(f) GDPR, record of the other person
Flight recordings (raw tracks, sensors)Archived; pilot identifier anonymised where neededArt. 6(1)(f) GDPR, flight-safety research
Polars, weather and registration-related dataPermanent (no personal reference)Not personal data
ATIS recordings and transcriptsUntil replaced by a newer retrieval; retrieval log as operational dataArt. 6(1)(b) GDPR
Vereinsflieger copies and request logCopies as long as the flight exists; request log 180 days; write log 365 daysArt. 6(1)(b) and (f) GDPR
Cockpit audio (microphone)Server: 90 days after the upload; on the device at most 14 daysArt. 6(1)(b) GDPR
Audio snippets and transcripts of the former radio transcription (until 13 October 2026)Until the account is deleted or upon request; processing logs 30 daysArt. 6(1)(b) GDPR
Personal documents (scans, identity document, medical)Until you delete them, at the latest until the account is deletedArt. 6(1)(b) GDPR
Aircraft papersAs long as the aircraft is kept in Skyminator, without reference to deleted accountsArt. 6(1)(b) GDPR, Part-ML M.A.305
Diagnostic and error logs90 daysArt. 6(1)(f) GDPR
Notifications, system messages90 days after reading; acknowledged system messages 365 daysArt. 6(1)(f) GDPR
Raw GPS data on the deviceAt most 7 daysArt. 5(1)(c) GDPR
API tokens, session dataUntil logout or expiryArt. 6(1)(b) GDPR
Consent log3 years after withdrawalArt. 7(1) GDPR

Our archive is on our own SFTP storage in Germany and accessible only to operator and administration staff. Archived content does not appear in your data export under section 7 because it either no longer has a personal reference or constitutes operational evidence of the archiving itself. If you delete your account, we delete your logbook completely (section 3.2), anonymise your identity in all other records unless a statutory retention period of third parties prevents it, and remove your name from the Vereinsflieger copies.

7. Your rights

You have the right of access (Art. 15 GDPR): under More → Account & security → Privacy → Download my data you receive a machine-readable export of all personal data we hold about you. Rectification (Art. 16) you perform directly in the app or by request. Erasure (Art. 17) is performed for retention-bound data as anonymisation after the statutory period. Restriction (Art. 18) is implemented as a flag on records. Data portability (Art. 20) is ensured via the JSON export with signatures for external verification. Objection (Art. 21) to consent-based and interest-based processing is possible at any time. Requests under Art. 16, 18, 20 and 21 can be made directly in the app under Privacy → Requests.

8. Consents, settings and withdrawal

We expressly log two consents: your agreement to this Privacy Policy and to the Terms of Use. You see both with date and version under Privacy → My consents. All other data flows are controlled by switches in the settings that take effect immediately: push notifications (system setting), location and background location (Flight & sensors → Location), share the whole flight, traffic receiver, show other traffic, winch-operator mode, Vereinsflieger transfer and device permission, WeGlide and logbook access grants. Switching off takes effect for the future; previous processing remains lawful. You withdraw the general consent to data use under section 4.3 by deleting your account; a separate opt-out would be incompatible with the purpose of the application.

9. Automated decisions (Art. 22 GDPR)

Skyminator makes no automated decisions with legal effect or similarly significant impact. Flight-time calculations, plausibility checks, route and altitude suggestions and polar analyses are computational or AI-assisted operations. The decision lies with the pilot.

10. Minors

Skyminator is aimed at pilots and student pilots from the minimum age of the respective training (microlight from 16, gliding from 14). Minors may use it only with the consent of their legal guardians; the consent under section 4.3 can be given for minors only by the legal guardians.

11. Technical and organisational measures

All transmissions use HTTPS or TLS. The local database on the device is encrypted with SQLCipher (AES-256). Private ECDSA keys for signatures are kept in the device's secure storage (Keychain on iOS, Keystore on Android) and secured by device attestation (App Attest, Play Integrity). Vereinsflieger credentials are stored encrypted. The audit trail is append-only and secured by a SHA-256 hash chain; the archive is designed as write-once SFTP storage. Passwords are stored exclusively as bcrypt hashes. We make regular backups and operate the entire infrastructure without third parties.

12. Right to lodge a complaint

You have the right to lodge a complaint with a data-protection supervisory authority. Competent for Diebold IT GmbH is the State Commissioner for Data Protection and Freedom of Information of Baden-Württemberg, Königstraße 10a, 70173 Stuttgart, Germany. Users in Georgia may additionally contact the Personal Data Protection Service of Georgia (pdps.ge).

13. Notice for users in Georgia

The controller is a company in the European Union; the GDPR applies. Insofar as the Law of Georgia on Personal Data Protection applies to you, you have the rights of access, rectification, erasure, restriction and objection provided there in the same way; you exercise them via the channels named in section 7. Your data is processed in Germany; a transfer to Georgia takes place only when you yourself access your account from there.

14. Consent, versioning and changes

By registering you agree to the current version of this Privacy Policy and of the Terms of Use. Which version you accepted is stored with timestamp, IP address and user agent (Art. 7(1) GDPR). Material changes are announced in good time in the app and by e-mail. When a new version takes effect you have 30 days to agree to it; meanwhile we show a notice and use remains unrestricted. If you do not agree, you may terminate your account extraordinarily within the period (Terms § 10.4); after the period has expired without agreement we may block the account (§ 10.5).

15. Language versions

This policy is available in German, English and Georgian. The German version is legally binding; the translations serve understanding.