Effective Date: January 1st, 2025
Last Updated: June 1st, 2025
1. Introduction
This Privacy Policy describes how Tower Talk ("we," "us," or "our") collects, uses, and shares information when you use our Aviation English practice platform, including our website at www.icaoenglish.org and mobile applications for Android and iOS (collectively, the "Service").
Our Service provides Aviation English practice materials based on ICAO standards for educational purposes only. Please note: Our Service does not replace official ICAO English training and does not issue any certificates or qualifications.
2. Information We Collect
2.1 Information You Provide
- Account Information: Name, email address, and other registration details
- Profile Information: Aviation experience level, learning preferences, and progress tracking data
- Practice Data: Your responses to exercises, quiz results, and performance metrics
- Audio Recordings: Voice recordings when you complete speaking exercises (stored temporarily for evaluation)
- Communications: Messages you send to us through support channels
2.2 Information Collected Automatically
- Device Information: Device type, operating system, unique device identifiers
- Usage Data: Pages visited, features used, time spent on exercises, app interactions
- Technical Data: IP address, browser type, language preferences, time zone
- Mobile App Data: App version, crash reports, performance analytics
2.3 Cookies and Tracking Technologies
We use cookies, web beacons, and similar technologies to:
- Remember your login status and preferences
- Analyze usage patterns and improve our Service
- Provide personalized learning recommendations
- Ensure security and prevent fraud
3. How We Use Your Information
We use the collected information to:
- Provide and Improve Service: Deliver practice exercises, track progress, and enhance learning experience
- Personalization: Customize content based on your skill level and learning patterns
- Communication: Send important updates, respond to support requests, and provide educational content
- Analytics: Understand usage patterns to improve our platform and develop new features
- Security: Protect against fraud, abuse, and security threats
- Legal Compliance: Meet legal obligations and enforce our terms of service
4. Information Sharing and Disclosure
We do not sell your personal information. We may share information in the following circumstances:
4.1 Service Providers
We work with third-party service providers who help us operate our platform:
- Cloud hosting and data storage providers
- Analytics and performance monitoring services
- Payment processors (for premium features)
- Customer support platforms
- Mobile app distribution platforms (Google Play, Apple App Store)
4.2 Legal Requirements
We may disclose information when required by law or to:
- Comply with legal processes or government requests
- Protect our rights, property, or safety
- Investigate potential violations of our terms
- Prevent fraud or security threats
4.3 Business Transfers
If we undergo a merger, acquisition, or sale of assets, your information may be transferred to the new entity.
5. Data Storage and Security
5.1 Data Storage
- Your data is stored on secure servers in United States.
- Audio recordings are automatically deleted after 10 days.
- Account data is retained while your account is active and for 30 days after deletion
5.2 Security Measures
We implement appropriate technical and organizational measures to protect your data:
- Encryption of data in transit and at rest
- Regular security assessments and updates
- Access controls and authentication mechanisms
- Secure development practices
6. Your Rights and Choices
Depending on your location, you may have the following rights:
6.1 Access and Portability
- Request access to your personal data
- Receive a copy of your data in a portable format
6.2 Correction and Deletion
- Correct inaccurate personal information
- Request deletion of your personal data (subject to legal requirements)
6.3 Processing Rights
- Object to certain processing activities
- Restrict processing in specific circumstances
- Withdraw consent for consent-based processing
6.4 Account Controls
You can:
- Update your profile information through account settings
- Adjust privacy preferences and communication settings
- Delete your account (which removes most personal data)
To exercise these rights, contact us at privacy@icaoenglish.org.
7. International Data Transfers
As our Service operates globally, your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place:
- EU Users: We comply with GDPR requirements for international transfers
- Standard Contractual Clauses: Used when transferring data outside the EEA
- Adequacy Decisions: We rely on adequacy decisions where available
8. Children's Privacy
Our Service is not intended for children under 14 (or applicable minimum age in your jurisdiction). We do not knowingly collect personal information from children. If we learn we have collected such information, we will delete it promptly.
9. Region-Specific Information
9.1 European Union (GDPR)
- Legal Basis: We process data based on legitimate interests, contract performance, or consent
- Data Protection Officer: Contact [DPO email] for privacy-related inquiries
- Supervisory Authority: You can lodge complaints with your local data protection authority
9.2 California (CCPA)
California residents have additional rights including:
- Right to know what personal information is collected
- Right to delete personal information
- Right to opt-out of sale (note: we do not sell personal information)
- Right to non-discrimination
9.3 Australia (Privacy Act)
We comply with Australian Privacy Principles regarding:
- Transparent data handling practices
- Individual access and correction rights
- Secure data management and breach notification
10. Third-Party Services
Our Service may contain links to third-party websites or integrate with external services. This Privacy Policy does not apply to those third parties. We encourage you to review their privacy policies.
11. Changes to This Policy
We may update this Privacy Policy periodically. We will:
- Post the updated policy on our website and mobile apps
- Notify you of material changes via email or in-app notification
- Update the "Last Updated" date at the top of this policy
12. Contact Information
For questions about this Privacy Policy or our data practices, contact us:
Email: info@icaoenglish.com