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Privacy and Cookie Policy

Privacy Policy  Flight Pilot Web and Mobile Application

Effective from: 1 January 2026
Version: 1.0

1. INTRODUCTION

1.1 Personal Data Controller
The controller of your personal data is:
Amevia s.r.o.
Registered office: Slezská 1736/99, 130 00 Prague 3
Company ID (IČO): 27634221
Tax ID (DIČ): CZ27634221

Email: [email protected]


Phone: +420 722 114 111

(hereinafter referred to as the “Controller” or “we”)

1.2 Purpose of this document
This document explains how we process your personal data in connection with the Flight Pilot mobile application (hereinafter the “Application”). It describes what data we collect, why we collect it, how we use it, and what rights you have.

1.3 Legal basis
We process personal data in accordance with:
- Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR)
- Act No. 110/2019 Coll., on the processing of personal data
- Other applicable legal regulations

1.4 Contact details of the Data Protection Officer
If you have any questions regarding the processing of personal data, please contact:

Email: [email protected]


Address: Slezská 1736/99, 130 00 Prague 3

2. WHAT PERSONAL DATA WE PROCESS

2.1 Basic data of all users
When you register and use the Application, we process:

A) Registration data:
- Email address
- Username (if you choose one)
- Password (in encrypted form)

B) Technical data:
- IP address
- Device type and operating system
- Device identifier (Android ID, Advertising ID)
- Application version
- System language
- Network information (connection type)

C) Game data:
- Game progress and achieved levels
- Game performance statistics
- Time spent in the game
- In-app purchases (if made)
- Interactions with advertisements (if displayed)

D) Application usage data:
- Date and time of login
- Frequency of use
- Clicks and interactions within the application
- Visits to individual sections

2.2 Extended data for Pilots/Promoters
If you become a Pilot (marketing promoter), we process the following in addition:

A) Identification data:
- Name and surname / Business name
- Date of birth / Company ID (IČO)
- Permanent residence / Registered office address
- Tax identification number (DIČ)
- ID document number (if required)

B) Payment data:
- Bank account number (IBAN)
- Bank code (BIC/SWIFT)
- Bank name

C) Tax data:
- Completed tax form
- Tax residence
- VAT payer status (if relevant)
- Other data required by tax regulations

D) Activity data:
- Number of referred players
- Amount of earned rewards
- Payment history
- Communication with our support

E) Other data:
- Phone number (optional)
- Information from your communication with us

2.3 Data we DO NOT COLLECT
We never process:
- Sensitive data (racial or ethnic origin, political opinions, religious beliefs)
- Biometric data (except where required for identity verification)
- Data on criminal convictions
- Precise GPS location (unless you explicitly allow it and it is strictly necessary)

3. WHY AND ON WHAT BASIS WE PROCESS YOUR DATA

3.1 Performance of a contract (Art. 6(1)(b) GDPR)
We process data necessary for:
- Creating and managing your game account
- Providing game services
- Ensuring the functionality of the Application
- For Pilots: calculation and payment of rewards, performance of the Promoter Agreement

Without this data, we cannot provide the service.

3.2 Compliance with legal obligations (Art. 6(1)(c) GDPR)
We process data for:
- Accounting and tax purposes (especially for Pilots)
- Archiving accounting documents
- Fulfilling requests from tax authorities
- Responding to requests from public authorities

3.3 Our legitimate interests (Art. 6(1)(f) GDPR)
We process data for:
- Fraud prevention and abuse detection
- Ensuring the security and stability of the Application
- User behavior analysis to improve services
- Marketing communication (with the option to unsubscribe)
- Enforcing our rights
- Protection against legal claims

We always weigh whether our interest outweighs your rights and freedoms.

3.4 Your consent (Art. 6(1)(a) GDPR)
For certain purposes we ask for your explicit consent:
- Sending marketing communications
- Use of third-party analytical tools
- Personalized advertising
- Tracking of precise location (if required)
- Sharing data with partners

You can withdraw your consent at any time in the Application settings or by contacting our support.

4. HOW LONG WE RETAIN YOUR DATA

4.1 Basic game data

| Type of data              | Retention period                          |
|---------------------------|-------------------------------------------|
| Active account            | Duration of use + 2 years after last activity |
| Deleted account           | 30 days (recovery option) → then anonymized |
| Technical logs            | 12 months                                 |
| Analytical data           | 24 months in anonymized form              |

4.2 Data of Pilots/Promoters

| Type of data              | Retention period                          |
|---------------------------|-------------------------------------------|
| Promoter agreement        | 10 years from termination (tax obligation)|
| Tax documents             | 10 years (legal obligation)               |
| Accounting documents      | 5 years (legal obligation)                |
| Payment data              | Until contract termination + 10 years     |
| Communication             | 3 years                                   |

4.3 Legal claims
If a court dispute is ongoing or may arise, we retain relevant data for the period necessary to assert or defend our rights.

4.4 Anonymization
After the retention period expires, we either delete the data or anonymize it (remove the possibility of identification).

5. TO WHOM WE SHARE YOUR DATA

5.1 Google Play and Google Pay
Reason: The Application is distributed via Google Play Store and payments are processed through Google Pay.
We share: purchase data, technical device data, crash and error information.
Legal basis: Performance of contract, technical necessity.

Google Privacy Policy: https://policies.google.com/privacy



5.2 Payment processors
For paying rewards to Pilots we use: banks and payment institutions.
We share: name and surname, account number, payment amount, purpose of payment.
Legal basis: Performance of contract.

5.3 Accounting and tax advisors
We share: billing data, tax information, Pilots’ accounting documents.
Legal basis: Compliance with legal obligations, legitimate interest.

5.4 Cloud and IT service providers
We use providers for hosting and operating the Application.
We share: technical and game data.
All providers are contractually bound to protect your data.

5.5 Analytical tools
With your consent we use Google Analytics for Firebase and others.
Purpose: Understanding user behavior and improving the Application.
You can opt out in the Application settings.

5.6 Advertising partners
If the Application displays ads (e.g. Google AdMob), we share: Advertising ID, technical data, ad interaction information.
You can disable personalization in your device settings (Reset Advertising ID).

5.7 Public authorities
We share data only when required by law, court order, or in case of suspected criminal activity.

5.8 Other cases
We may share data in case of company merger/acquisition (with your consent) or to protect our legal interests and user safety.
We never sell your personal data to third parties for their marketing purposes.

6. TRANSFERS OF DATA TO THIRD COUNTRIES

6.1 Countries outside the EU/EEA
Some of our service providers are located outside the European Union, especially in the USA (cloud services, analytics).

6.2 Protection safeguards
We ensure protection through:
- EU Standard Contractual Clauses
- Adequacy decisions
- Certifications (e.g. Privacy Shield where applicable)

6.3 Your rights
You have the right to obtain a copy of the safeguards we have implemented. Contact us at [email protected].

7. YOUR RIGHTS

7.1 Right of access (Art. 15 GDPR)
7.2 Right to rectification (Art. 16 GDPR)
7.3 Right to erasure (“right to be forgotten”) (Art. 17 GDPR)
7.4 Right to restriction of processing (Art. 18 GDPR)
7.5 Right to data portability (Art. 20 GDPR)
7.6 Right to object (Art. 21 GDPR)
7.7 Right to withdraw consent (Art. 7 GDPR)
7.8 Right to lodge a complaint (Art. 77 GDPR) – with the Czech Data Protection Authority (ÚOOÚ).

7.9 How to exercise your rights

- Email: [email protected]


- In the Application (section “My Data” / Settings)
- By post to the company address

We respond within 30 days (60 days in complex cases). Identity verification may be required. Exercising rights is free of charge (except for manifestly unfounded or excessive requests).

8. SECURITY OF YOUR DATA

We use technical (encryption, access control, firewalls, regular updates) and organizational measures (staff training, contracts with processors, audits, incident response plan) to protect your data.

9. CHILDREN AND MINORS

The Application is intended for persons over 18 years of age. Users under 18 may use it only with the consent of a legal guardian. We do not knowingly collect data from children under 13 without parental consent.

10. COOKIES AND TRACKING TECHNOLOGIES

We use necessary, functional, analytical, and advertising cookies. You can manage them in the Application settings or your browser/device settings.

11. CHANGES TO THIS PRIVACY POLICY

We will inform you of significant changes via the Application, email, or push notification at least 30 days in advance (where possible). You may stop using the Application or delete your account if you disagree.

12. CONTACT INFORMATION

Controller: Amevia s.r.o., Slezská 1736/99, 130 00 Prague 3

Data protection contact: [email protected]


DPO: [email protected]


Supervisory authority: Úřad pro ochranu osobních údajů (https://www.uoou.cz)

13. FINAL PROVISIONS

These principles enter into force on the stated date. In case of any discrepancy between the Czech and English versions, the Czech version prevails. These principles are governed by the laws of the Czech Republic.

Last update: 1.6.2026

Thank you for your trust! Your privacy is our priority. If you have any questions, please contact us at [email protected].

Attachments
- Appendix 1: GDPR definitions
- Appendix 2: List of processors (available on request)

- Appendix 3: Data Protection Impact Assessment (DPIA) (available on request)


Cookie Policy

Cookies are small bits of text sent by our servers to your computer or device when you access our services. They are stored in your browser and later sent back to our servers so that we can provide contextual content. Without cookies, using the web would be a much more frustrating experience. We use them to support your activities on our website. For example, your session (so you don't have to login again) or your shopping cart.
Cookies are also used to help us understand your preferences based on previous or current activity on our website (the pages you have visited), your language and country, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Here is an overview of the cookies that may be stored on your device when you visit our website:

Category of Cookie Purpose Examples

Session & Security
(essential)

Authenticate users, protect user data and allow the website to deliver the services users expects, such as maintaining the content of their cart, or allowing file uploads.

The website will not work properly if you reject or discard those cookies.

 session_id 

Preferences
(essential)

Remember information about the preferred look or behavior of the website, such as your preferred language or region.

Your experience may be degraded if you discard those cookies, but the website will still work.

 frontend_lang 
Interaction History
(optional)

Used to collect information about your interactions with the website, the pages you've seen, and any specific marketing campaign that brought you to the website.

We may not be able to provide the best service to you if you reject those cookies, but the website will work.

 im_livechat_previous_operator 
utm_campaign 
utm_source 
utm_medium 

Advertising & Marketing
(optional)

Used to make advertising more engaging to users and more valuable to publishers and advertisers, such as providing more relevant ads when you visit other websites that display ads or to improve reporting on ad campaign performance.

Note that some third-party services may install additional cookies on your browser in order to identify you.

You may opt-out of a third-party's use of cookies by visiting the Network Advertising Initiative opt-out page. The website will still work if you reject or discard those cookies.

__gads (Google)
__gac (Google)

Analytics
(optional)

Understand how visitors engage with our website, via Google Analytics. Learn more about Analytics cookies and privacy information.

The website will still work if you reject or discard those cookies.

 _ga (Google)
_gat (Google)
_gid (Google)
_gac_* (Google)

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

We do not currently support Do Not Track signals, as there is no industry standard for compliance.