Privacy Policy
This Privacy Policy explains how [PUBLISHER LEGAL NAME] ("we", "us", "CrewHub", "Oenair") collects and processes personal data when you use our websites (oenia.eu and its sub-domains), the CrewHub web application, and our desktop software (CrewHub Installer, CrewHub Acars, CrewHub desktop).
1. Data controller
The controller responsible for your personal data is:
- Controller: [PUBLISHER LEGAL NAME / LEGAL FORM]
- Address: [ADDRESS]
- Contact / privacy requests: [PRIVACY EMAIL]
- Data Protection Officer (if appointed): [DPO NAME / EMAIL or "not appointed"]
2. What data we collect
| Category | Examples | Source |
|---|---|---|
| Account | Email, display name, first/last name, password (stored hashed), role/rank, airline membership | You, at registration |
| Network IDs (optional) | IVAO ID, VATSIM ID, SimBrief username, Discord ID | You |
| Simulation activity | Flight reports (PIREPs), bookings, live positions, statistics, in-game balance and progress | Generated as you use the service / the Acars client |
| Technical | IP address, browser/app version, approximate timestamps, error logs | Collected automatically |
| Communications | Support messages and their content | You |
We do not knowingly collect special-category data, and the platform is intended for flight-simulation hobbyists, not children under [AGE, e.g. 16].
3. Why we use it & legal basis (Art. 6 GDPR)
| Purpose | Legal basis |
|---|---|
| Create and operate your account, deliver the service | Performance of a contract (Art. 6(1)(b)) |
| Record and review flight reports, run the virtual airline features | Performance of a contract / legitimate interests |
| Security, fraud/abuse prevention, debugging | Legitimate interests (Art. 6(1)(f)) |
| Optional integrations (SimBrief, Discord, networks) | Consent (Art. 6(1)(a)) — given by linking the account |
| Legal obligations (where applicable) | Legal obligation (Art. 6(1)(c)) |
4. Sharing & third parties
We do not sell your personal data. We share it only with service providers (processors) acting on our instructions, and with third-party services you choose to connect:
- Hosting / infrastructure: [HOST NAME], Cloudflare (CDN/DNS).
- SimBrief (flight planning) — when you provide your SimBrief username.
- Discord — if you use Discord features / Rich Presence.
- Networks (IVAO / VATSIM / POSCON) — only the IDs you choose to display.
5. International transfers
Where a provider processes data outside the EEA, we rely on appropriate safeguards (e.g. EU Standard Contractual Clauses). Details: [PRIVACY EMAIL].
6. Retention
We keep account data while your account is active and for [X months/years] after closure, then delete or anonymise it. Technical logs are kept for [X days/months]. Backups are rotated on a [X] cycle.
7. Your rights (Art. 15–22 GDPR)
You have the right to: access, rectification, erasure ("right to be forgotten"), restriction, data portability, objection, and to withdraw consent at any time. You can exercise most of these from your CrewHub profile, or by contacting [PRIVACY EMAIL]. You also have the right to lodge a complaint with your supervisory authority (in France: the CNIL, cnil.fr).
8. Security
Passwords are stored hashed; traffic is encrypted in transit (HTTPS/TLS). Access to personal data is restricted to authorised staff. No method of transmission or storage is 100% secure.
9. Cookies
See our Cookie Policy.
10. Changes
We may update this policy; the "last updated" date reflects the latest version. Material changes will be notified in-app or by email.
11. Contact
Questions or requests: [PRIVACY EMAIL].