FRTOL01In Short
- There's no sign-in. We don't ask for your name, email address, phone number or location.
- No adverts, no tracking, no analytics, and we never sell your data.
- Your voice is turned into text on your iPhone. We don't receive or keep recordings.
- To run the AI controller, voices and debriefs, the text of your practice calls is processed by our service providers. We don't store it.
- You can delete your account from the App at any time.
02Who Is Responsible for Your Data
Xynnar Group Ltd ("we", "us"), a company registered in England and Wales (company number 16167212), is the data controller for personal data processed through the FRTOL app and frtol.app. Contact us about privacy through the support link on FRTOL's App Store page.
We process personal data under the UK GDPR and the Data Protection Act 2018 and, where it applies to you, the EU GDPR.
03What We Collect and Why
| Data | What it is | Why | Lawful basis |
|---|---|---|---|
| Install and account | A random account ID, a device token (stored by us only in scrambled, hashed form), your minutes balance and history, your invite code and who invited you, and the terms version you agreed to and when | To run your account and flight time, and to keep a record that you agreed to our Terms | Contract; legitimate interests |
| Purchases | Apple's signed record of each purchase: product, date, transaction numbers and a random account reference. We never see your card details, name or Apple Account | To add flight time, prevent the same purchase being counted twice, handle refunds and Restore | Contract; legal obligation (records) |
| Flight usage | When each flight started, paused and ended, the minutes used, and whether a debrief was given | To charge flight time fairly and prevent misuse | Contract; legitimate interests |
| Practice radio calls | The text of your practice calls, the controller's replies and facts about your simulated flight (such as simulated position, frequency and squawk) | To produce AI controller replies, natural voices and debriefs | Contract |
| Technical data | Your IP address, request times and app version, in server logs and fair-use counters | To keep the Service secure and working, and to apply fair-use limits | Legitimate interests |
| Blocked calls | A count, for the current day only, of practice calls blocked for profanity or for trying to misuse the AI, and the type of block. We don't keep the words used | To keep the AI to radio practice, protect younger users and pause the AI after repeated misuse | Legitimate interests |
| Messages to us | Anything you send if you email us | To reply and help you | Legitimate interests |
We don't collect your real location, contacts, photos, advertising identifier, health data or any special category data. We don't make decisions about you based solely on automated processing that have legal or similarly significant effects.
04What Stays on Your iPhone
- Your voice. The App only listens while you hold the talk button. Speech is turned into text on your iPhone and the audio isn't kept or sent to us. While the speech model is first downloading, the App may use the iPhone's own dictation, which Apple may process under its privacy policy.
- Settings, exam results and debriefs are stored on your iPhone. Your device token is kept in the iPhone's Keychain.
- Navigation app link. If you turn it on, your simulated position is sent to your navigation app over your local network only.
06International Transfers
Some providers are outside the UK and the EEA, in particular in the United States. Where we transfer personal data to a country without an adequacy decision, we rely on appropriate safeguards, such as standard contractual clauses or the UK International Data Transfer Addendum, or another lawful transfer mechanism. Contact us for more information.
07How Long We Keep Data
- Account, minutes and flight records: until you delete your account. We may delete accounts that have been inactive for a long period.
- Purchase records: kept after account deletion, without any link to you, so that a purchase can't be counted twice, and for as long as needed for accounting and legal purposes.
- Practice call text: not stored by us; it's processed to produce each reply and then discarded. Our providers may keep it briefly under their own retention terms, for example to detect abuse.
- Server logs and fair-use counters: for a short period.
08Your Rights
Depending on where you live, you have the right to access your data, to correct it, to have it deleted, to restrict or object to its processing, and to data portability. You can delete your account at any time in Settings › Flight time.
Because there's no sign-in, we can only identify your data from your Account ID, shown in Settings › Flight time. Include it when you contact us through the support link on FRTOL's App Store page. We'll reply within one month.
If you're unhappy with how we've handled your data, please tell us first. You can also complain to the Information Commissioner's Office (ico.org.uk) or, if you live in the EU, your local data protection authority.
09Children
The Service isn't intended for children under 13, and we don't knowingly collect personal data from them. Users aged 13 to 17 must have a parent's or guardian's permission. If you believe a child under 13 has used the Service, contact us and we'll delete the account.
10Security
We use encryption in transit (HTTPS), store device tokens only in hashed form, verify every App Store purchase cryptographically and limit access to our systems. No system is completely secure, but we work to protect your data and will notify you and the regulator of a breach where the law requires.
11Changes to This Policy
We may update this policy. We'll show the date of the latest version here and, for significant changes, tell you in the App. Last updated 7 November 2026.