AVIOFILE App Privacy Notice
Do you use the AVIOFILE app (iOS, Android or app.aviofile.com)? The App Terms of Use and the App Privacy Notice apply, available in Italian and English. Italiano
Version: 2026-10-20 In force from: 20 October 2026
This notice explains, under arts. 13 and 14 of Regulation (EU) 2016/679 ("GDPR"), which personal data AVIOFILE processes, why, for how long, with whom it is shared and what rights you have. We try to be clear and concrete; where the situation is complex (for example after an account is deleted) we say so openly.
1. Who is the data controller
The controller is DIMMA S.r.l. ("AVIOFILE", "we"), Via Roma 84/A, 37060 Castel d'Azzano (VR), Italy, VAT and tax code 03650380235, REA VR 353748, share capital € 10,000.00, PEC dimma@pec.it.
Contact for any personal-data matter: privacy@aviofile.com. For general support: support@aviofile.com. We have not appointed a Data Protection Officer (DPO) because we do not consider ourselves required to.
2. Roles: us and organisations
AVIOFILE processes data in two ways.
- Account and service data. When you create an account, use your personal logbook, receive notifications, export or delete your data, we decide the purposes and means: we are the controller.
- Data an organisation keeps about its members. An organisation (co-owners' group, club, school, workshop) uses AVIOFILE to manage members, students, training records, documents about members, receipts, accounts and bookings. For this data the organisation decides the purposes and is an independent controller towards its own members; we process it on its behalf, as processor (art. 28 GDPR), within the limits of the Terms of Use and the agreement for organisations. If you want to exercise a right over this data, also write to the organisation (see art. 10).
3. What data we process
| Category | Examples | Where it comes from |
|---|---|---|
| Account and sign-in | email, first and last name, language, time zone, home airfield, technical account identifiers; if you sign in with Apple or Google, the identifier they give us and the email/name you choose to share (Apple may hide the email); sessions and, once push notifications are active, the device token | you, Apple/Google |
| Password | handled by our sign-in provider (Amazon Cognito); we do not see it | you |
| Logbook and flight data | flights, times, airfields, on-board role, landings, notes, personal entries (external flights, simulator, brought-forward totals), totals | you and members of the same organisation who record the flight; file imports |
| Licences, ratings, medical, personal documents | licence types and numbers, expiry dates, medical certificate dates, attached files (PDF, photos) | you |
| Aircraft and records | aircraft, components, maintenance work and who performed or certified it, defects, bookings, ownership shares | you and organisations |
| Organisation and roles | memberships, roles, invitations, permissions, change history | you, administrators |
| Training | course enrolments, lessons, assessments, notes, instructors' signatures | schools and instructors, students |
| Costs, balances and receipts | shared costs, payments, prepaid wallets, membership dues, non-fiscal receipts showing the payer's name. During the preview we do not process cards or other payment methods | you and organisations |
| Messages and communications | in-app notifications, service emails (invitations, deadlines, confirmations), messages to support and to the privacy mailbox | you and the system |
| Consents | versions of the Terms and Privacy Notice accepted, dates, choice about promotional emails | you |
| Technical and security data | IP address and connection data in technical logs, change log (who, when, what) for security and integrity | the system |
| Diagnostic data | when the app or the website stops or fails: type of error, message and the places in the code where it happened, cleaned of emails, tokens, identifiers and text you wrote; app version, platform and system, language, screen (without identifiers), a random installation identifier; if you are signed in, a pseudonym of your user, which only we, with a secret key, can link back to your account to give you support (the log holds no identifier, email or name of yours) | the app and the website, automatically |
| Free-trial anti-abuse check | a fingerprint (SHA-256 hash) of your email address, the plan type and the date, without the email itself or other data that directly identifies you | the system |
| Assisted import ("Ci pensiamo noi"), if you use it | photos and files of the logbook or technical log you send us, a note, the request status | you |
Health data. The medical certificate (expiry date and any file) is data concerning health (art. 9 GDPR). See art. 6. We treat it as such even when you enter only class and expiry date without the file: they reveal your medical fitness to fly.
Card payments on the website (Stripe), when active. Organisation and subscription, payment status, Stripe customer and subscription identifiers, last digits and expiry of the card as Stripe shows them to us, whether you are a consumer and when you asked for the service to start immediately (for withdrawal). Only Stripe processes the full card number.
We do not collect your location or your phone contacts, and we do not use third-party analytics or advertising tools in the app. Diagnostic data goes to our servers in Europe, not to third-party services.
Billing data and in-app purchases (draft, docs/52). For direct contracts with DIMMA only: name, e-mail and country of a private person (address and tax code if an invoice is asked for), or company name, VAT number, tax code, registered office, SDI code or PEC and billing e-mail of a business or body; the outcome of the VIES check of the VAT number; the payments received, the invoices and payment confirmations with a copy of the billing data of the time (kept 10 years by law). No card numbers. Legal bases: contract (art. 6.1.b) and legal obligation (art. 6.1.c). Recipients: the Italian Revenue Agency (SDI), DIMMA's accountant, the European Commission (VAT number only, VIES), the e-invoicing provider and, when card payments start on the website, Stripe. For in-app purchases we receive from Apple and Google the product, dates, status, transaction or order id, store country and (Apple) price and currency: never your name, e-mail or payment data. The billing data of your personal account are erased with the account; the invoices already issued stay for the legal period.
4. Data about other people entered by you or your organisation
By using AVIOFILE you will enter, or find, data about other people: names of crew and passengers, instructors, students, co-owners (and their emails when you invite them), maintenance staff who performed or certified work, club members; and, in photos and files for assisted import, names, signatures and sometimes licence numbers of third parties.
If your data was given to us by others, we received it from the user or organisation that entered it (art. 14 GDPR). We use it only for the service purposes described above: keeping the aircraft's, logbook's, organisation's and courses' records and accounts. We do not use it to contact you for promotional purposes. You may exercise your rights as explained in art. 10 even if you have no account; in that case we may ask you to prove who you are and where you appear. For practical reasons (a name written by hand in a record may not be traceable to an account) we cannot always inform every person named in a record individually: we do so through this general notice.
Anyone who enters data about other people must do so only where relevant and lawful (Terms of Use, art. 7).
5. Why we process data and on what legal basis
| Purpose | Legal basis |
|---|---|
| Create and manage the account, let you sign in, provide the service (logbook, aircraft, organisations, notifications, exports) | Contract (art. 6.1.b) |
| Send you service emails and notifications: invitations, licence and document deadlines, confirmations, notices about deletion | Contract; for security and legal notices, legitimate interest |
| Let organisations manage members, records, bookings, accounts and documents | Contract with you and with the organisation; legitimate interest of the organisation and of other participants in keeping complete records (art. 6.1.f) |
| Keep records the law requires of the organisation or of the owner/operator (for example maintenance, training, accounting records) | Legal obligation of whoever keeps them (art. 6.1.c), for the part that falls to us as processor |
| Share licence and medical expiry dates with a club or school, and, with a second consent, open attached files | Consent (art. 6.1.a; for medical files, explicit consent, art. 9.2.a), given per organisation and withdrawable at any time |
| Assisted import ("Ci pensiamo noi") | Contract (the service you request); for third parties' data in photos, your and our legitimate interest in keeping and transcribing an accurate logbook |
| Finding and fixing errors and crashes of the app and the website (diagnostics) | Legitimate interest (art. 6.1.f) in keeping the service working and secure, with data reduced to the minimum; you can object at any time by turning off Send diagnostic data in Privacy & information |
| Security, fraud and abuse prevention, change log (audit), defence of legal claims | Legitimate interest (art. 6.1.f); for what the law requires, legal obligation |
| Prevent the same person from using the free trial more than once (email fingerprint) | Legitimate interest (art. 6.1.f) in preventing abuse, with data reduced to the minimum |
| Consent records and accepted versions | Duty to demonstrate consent (art. 7.1) and legitimate interest |
| Legal and accounting obligations | Legal obligation (art. 6.1.c) |
| Reply to requests sent to support@ and privacy@ | Contract or legitimate interest; legal obligation for data-rights requests |
| Recording your medical certificate in your file (class, expiry, file) | Explicit consent (art. 9.2.a): entering it is optional and done by you; you withdraw consent by deleting the certificate |
| Card payments on the website: subscription, renewals, refunds, withdrawal, fraud prevention | Contract (art. 6.1.b); legal obligation for accounting and withdrawal (art. 6.1.c); legitimate interest in fraud prevention (art. 6.1.f) |
| Handling personal data breaches: register, notifications to the authority, notices to you and to organisations | Legal obligation (Arts. 33-34 GDPR, art. 6.1.c) |
| Receiving and handling reports of illegal content and complaints (DSA) | Legal obligation (Regulation (EU) 2022/2065, Arts. 16-17; art. 6.1.c) and legitimate interest |
| Promotional emails or news (optional) | Consent (art. 6.1.a), separate, off by default, withdrawable at any time in Privacy & information |
We do not take decisions based solely on automated processing that produce legal effects on you. The app's reminders and calculations (deadlines, currency, balances) are aids computed from the data you enter, not decisions about you. We do not profile for commercial purposes.
6. Health data and sensitive documents
- What. A pilot's medical certificate: the expiry date, the class and, if you upload it, the file. It may also appear in identity documents or other files you upload.
- Why. To remind you of deadlines and keep it in your personal file. Entering it is optional: we process it on the basis of your explicit consent (art. 9.2.a), which you withdraw by deleting the certificate; without it you can use everything else in the app.
- Minors. If the student is a minor, health data are entered by the school, with parental authorisation, or by the parent.
- Who sees it. Only you. A club or school sees only the expiry dates of your licences and medical certificates if you allow it for that organisation; it sees attached files only with a second, separate consent. Both consents can be withdrawn at any time; every time an organisation opens a file it is logged. If the organisation downloads a copy, that copy is its responsibility.
- Documents uploaded about you by organisations. A school or club may upload documents to your member profile (identity, medical, licence, receipts). For these documents the organisation is the controller (art. 2): ask it where they are kept and for how long.
7. Who we share data with
Other users. Data is visible only to those entitled to it by role and permissions. Examples: members of your organisation see what their role allows; whoever flies the same aircraft sees that flight's data, including your name as a crew member; co-owners see the group's accounts; a school or club may see logbook lines of flights made with its own aircraft, even after you have left the organisation. Other users do not see your personal logbook or your documents.
Our staff. Only authorised DIMMA personnel, for support, security and maintenance of the service, to the extent necessary and with logging of the most sensitive accesses.
Providers (processors and recipients)
| Provider | What it does | Where |
|---|---|---|
| Amazon Web Services (AWS) | service infrastructure: database (DynamoDB), files (S3), sign-in and accounts (Cognito), functions (Lambda), antivirus scanning of uploaded files (GuardDuty), sending and receiving service emails (SES), content delivery and logs. Acts as our processor | Europe (Frankfurt, `eu-central-1`) |
| Apple | "Continue with Apple" (if you choose it); distribution of the app and TestFlight on the App Store; iOS push notifications (APNs) once active | Apple acts as independent controller for its own services; see its notice |
| "Continue with Google" (if you choose it); distribution of the app on Google Play; Android push notifications (FCM) once active | Google acts as independent controller for its own services; see its notice |
We do not sell data and do not share it with advertisers. We may disclose data to authorities or advisers (legal, tax, insurance) when the law requires or to defend a right.
8. Transfers outside the European Economic Area
App data is stored in Europe (Frankfurt). Some providers belong to groups headquartered in the United States (Amazon, Apple, Google) and may, in limited cases (for example technical support, or the Apple/Google sign-in services you choose to use), process data from outside the EEA. In those cases the transfer is based on a European Commission adequacy decision (EU-US Data Privacy Framework) or on standard contractual clauses approved by the Commission, with the supplementary measures required. You can ask for a copy of the safeguards by writing to privacy@aviofile.com. Participants in the EU-US framework (adequacy decision (EU) 2023/1795, upheld by the EU General Court on 03/09/2025 in case T-553/23, appeal pending as C-703/25 P): Amazon Web Services, Google LLC and Stripe, LLC. Apple is not listed: for Apple the standard contractual clauses (Decision (EU) 2021/914) in its contracts apply. If the adequacy decision were annulled, the standard contractual clauses already provided in the AWS, Google and Stripe contracts would apply.
9. How long we keep data
While you use the account, we keep data to provide the service. When you delete the account (art. 10) there is a 14-day period in which you can change your mind; after that:
| Data | What happens | When |
|---|---|---|
| Profile (name, email, base, language), sign-in identity, sessions, tokens | deleted or made non-attributable to you | profile: right after the 14 days; sessions and tokens: on confirmation |
| Licences, ratings, medical, personal documents and files, personal logbook entries, notifications, preferences | deleted | database within about 2 days; files within about 31 days |
| Exports already generated | deleted | at most 7 days after creation (2 days after deletion) |
| Assisted-import requests and files | cancelled or discarded files deleted within 1-2 days; open requests cancelled | files: at most 30 days after the request is closed |
| Backups | expire on their own; deleted data may remain in backups | up to 35 days |
| Flights and crew lines on aircraft, maintenance records, past bookings, historical ownership shares, memberships and invitations, change history | remain in records shared with other people, with your name replaced by "Removed user" (pseudonymisation: the internal identifier stays to keep the records consistent, but no longer leads to a name) | for as long as the aircraft or organisation must keep the record |
| Training records already signed | the instructor's and signer's name stays in the record because it is part of the signature; the student's enrolments are pseudonymised | for the duration of the school's retention obligation |
| Costs, payments, wallet and dues receipts | kept for accounting obligations; receipts show the payer's name | up to 10 years (art. 2220 Italian Civil Code) |
| Documents an organisation uploaded about you | remain with the organisation | the organisation decides |
| Consent records | remain, with dates and versions, without further personal data | |
| Email fingerprint for the free trial | remains, because its very purpose is to survive deletion | no fixed expiry yet: we are limiting it to 24 months |
| Messages to support@ and privacy@ | kept to reply and for legal obligations | up to 2 years; data-rights requests 5 years |
| Data breach register and data-rights requests | kept to show we complied with the law | 5 years from closure |
| Reports of illegal content and complaints | kept to reply and to defend decisions | 2 years |
| Diagnostic reports (errors and crashes) | deleted automatically | 90 days from the report; the anti-abuse check keeps only a fingerprint of the IP address, for at most 2 days |
Some notes: the notification inbox is emptied after 180 days; technical logs are kept for a limited period (up to 90 days); cancelled or expired assisted-import requests are deleted according to the table.
We do not delete any data at the end of the preview.
Backups and restores. Backups are used only to restore the service after a failure or an attack. If we have to restore one, before putting the data back online we re-run the account deletions requested after the restored point in time, so a restore never brings deleted data back.
Recipients: Stripe and internal tools. When card payments on the website are active, Stripe (Stripe Payments Europe Ltd., Ireland; group based in the USA) collects payments, runs the portal for cancellation and card changes, and handles refunds; it acts on our behalf for the payment service and as an independent controller for its own obligations (fraud prevention, anti-money-laundering, card scheme rules). We do not give your data to external artificial-intelligence services; for support we use the data in the service, with access logged.
Important. What remains in shared records after deletion is pseudonymised, not anonymous: someone who knows the context may recognise you. We keep it because it is needed by other people (a flight involves several people, and the others are entitled to their own logbook), or because an aircraft, school or accounting record must be retained (art. 17.3(b) and (e) GDPR).
10. Your rights and how to exercise them
You have the right to access your data, rectify it, erase it, restrict processing, object to processing based on legitimate interest, receive your data in a portable format and withdraw consent (withdrawal does not affect processing already carried out).
In the app, without writing to anyone
- Access and take your data with you: Export my data. You get a ZIP archive (JSON, CSV, PDF) with your profile, consents, licences, organisations, logbook, bookings, wallets and receipts, notifications, the history of your records and more; it is ready in a few minutes, we notify you by email and it can be downloaded for 7 days. Files attached to documents are not copied into the archive, but are listed with the path to download them.
- Rectify: you can edit your profile, licences and personal logbook entries; corrections to an aircraft's or organisation's records are made by whoever manages them.
- Delete the account: Delete account (art. 9 and Terms, art. 12).
- Consents: in Privacy & information you can switch promotional emails on or off and see which versions of the Terms and Notice you accepted; sharing of licences and medical certificates with an organisation is withdrawn from the organisation/document settings.
For everything else: write to privacy@aviofile.com. We reply within one month (extendable by two months for complex cases, with notice). We may ask you to verify your identity. For data held by an organisation (records, documents about members, receipts) the request also goes to the organisation, which is the controller; we help you identify it. If you have no account or have already deleted it, tell us where you appear (aircraft, school, date) so that we can find you; after deletion we may no longer be able to identify you with certainty (art. 11 GDPR).
Deceased persons. Rights over the data of a deceased person may be exercised by whoever has an interest of their own, acts to protect the person as their agent, or for family reasons deserving protection, unless the person prohibited it in writing (Art. 2-terdecies of the Italian Privacy Code). Write to privacy@aviofile.com with documents proving the death and your entitlement.
11. Complaint to the supervisory authority
If you believe we process your data in breach of the law, you may lodge a complaint with the supervisory authority of the country where you live, work or where the alleged infringement took place. In Italy this is the Garante per la protezione dei dati personali (www.garanteprivacy.it). If you wish, please contact us first: we try to resolve matters straight away.
12. Children
The app is intended for people who are at least 16 years old. We do not knowingly collect data of younger persons. If you think a minor has given us their data, write to privacy@aviofile.com and we will delete it. Schools enrolling minor students must obtain parental authorisations and may not use AVIOFILE to create accounts in the name of minors without meeting these requirements. In Italy a person aged 14 or over can give consent to online services on their own (Art. 2-quinquies of the Italian Privacy Code); the contract and purchases still require an adult. Therefore: personal account from 16, with a parent's agreement until 18; at 14-15 only when a school enrols the student with parental authorisation; no purchases by minors; for minor students health data are entered by the school or the parent.
13. Security
We use appropriate technical and organisational measures, including:
- encrypted connections (HTTPS) and data encrypted at rest; separation of data between organisations, with permission checks on every request;
- multi-factor sign-in for platform administrators and least-privilege permissions for internal systems;
- antivirus scanning of uploaded files before they are made available;
- a change log that users cannot alter, and logging of openings of sensitive documents;
- backups with point-in-time restore (up to 35 days back);
- procedures to handle any data breach, with notification to the authority and to individuals where the law requires.
If something happens. We keep a register of every personal data breach. If a breach may result in a risk to you, we notify the Italian authority within 72 hours of becoming aware of it; if the risk is high, we also inform you, by email and in the app, saying what happened, which data, what we did and what we recommend (Arts. 33-34 GDPR). If the data are those your organisation manages in AVIOFILE, we promptly inform the organisation, which as controller decides on notifications. To report a vulnerability: security@aviofile.com.
No system is 100% secure: choose a strong password, do not share it, and report problems to support@aviofile.com straight away.
14. Cookies and local storage (app and web app)
The app does not use profiling cookies or third-party analytics or advertising tools. To work, the app stores on your device (and, in the web app, in the browser's local storage) only information that is strictly necessary or requested by you: the sign-in session, the language and theme chosen, the last view used, the draft of a technical-log transcription in progress (which may contain names), a marker remembering that you ticked acceptance of the Terms at sign-up and that the app has been installed (to close sessions left over after a reinstall), and similar preferences. These are not used to track you and do not leave the device except to authenticate with the service. Since they are strictly necessary they do not require your consent (art. 122 Italian Privacy Code); you can delete them from the browser settings or by uninstalling the app, but some functions (for example staying signed in) will not work. The aviofile.com website has its own cookie notice.
Identifier for diagnostics. For diagnostics (art. 3) the app stores a random installation identifier on the device. It is used only while Send diagnostic data is on: you can turn it off at any time in Privacy & information.
15. Changes to this notice
When our practices change we update this page and the date at the top. For material changes we notify you in the app and ask you to accept the new version. Material changes (new purposes, new recipients, new transfers) are communicated before they apply, by email and in the app; a new purpose based on consent starts only if you consent. We keep all published versions with their dates. Previously accepted versions remain on record. Translations are courtesy translations; the reference text indicated in the Terms prevails.
16. Contact
- Controller: DIMMA S.r.l., Via Roma 84/A, 37060 Castel d'Azzano (VR) — VAT no. 03650380235 — PEC dimma@pec.it
- Privacy and data rights: privacy@aviofile.com
- Support: support@aviofile.com