DRAFTDraft, under review by our lawyer. The reviewed version will be part of your agreement.
Privacy notice
Last changed 03.11.2026. A draft: the reviewed text will be part of your agreement.
AeroViktros is software that maintenance organisations (MROs) and CAMOs use for their work packages, job cards, stamps, CRS and airworthiness records. The organisation that uses AeroViktros decides about the data it records about its staff, its customers and its aircraft; we process that data for it.
1. Who we are
[owner/lawyer: the legal name of the company that runs AeroViktros], [owner/lawyer: the registered address], [owner/lawyer: the company number (UIC / EIK) and VAT number], runs AeroViktros ("we").
Privacy questions: office@aeroviktros.com. Data protection officer: [owner/lawyer: whether a data protection officer is required, and who].
2. Who decides about your data
- The maintenance organisation is the controller of what it records in AeroViktros: its staff accounts, the work they sign, its customers' aircraft and the customers' portal accounts. AeroViktros is its processor and acts only on its instructions, under a data processing agreement (DPA).
- AeroViktros is the controller only for (a) contact and trial requests sent through this site ("leads") and (b) the accounts of its own people who run the platform.
3. What is collected
| Whose | What |
|---|---|
| Staff of a maintenance organisation | Name, e-mail, phone (optional), login name, role, photo (optional), password (stored only as an Argon2id hash), the certifying staff register (authorisation and licence numbers, categories, scope, validity), NDT qualifications; the work they record and sign: stamps, CRS, times on the clock, comments, photos and files. |
| Staff - training and NDT vision exams | Training records (kind, dates, valid until) with their evidence (a certificate file), and who entered them. For NDT staff, the vision exam: only its date, its validity and the examiner (EN 4179) - never a result or a diagnosis. |
| Staff who report a safety event, and people named in a report | Occurrence reports: what happened, where, when, the category, and the reporter's name. A confidential report keeps no name on the report: the name is in a separate table that only the Manager / quality role reads; other staff see the report without the card, the place or the time of day. |
| Auditors, owners of findings, Quality | Audits, audit findings and CAPA: who raised, owns, proposed and closed them (name and number), with dates and evidence files. |
| Customer portal accounts | Name, e-mail, login name, the aircraft linked to the account, the decisions given in the portal. |
| People who send a contact or trial request | Name, company, e-mail, phone (optional), country, the request and its message, fleet and module details given in the form. |
| Everyone who signs in | Technical records of use: time, the address of the page, the result, the IP address and the browser; a record of every change (who, when, what kind) - the audit trail. Sign-in sessions: the device shortened ("Chrome on Windows"), the IP address's prefix only, when it started and was last used. The cookies on Cookies. |
| Users of the AI features | What the person sends to the AI feature (text, pictures, pages) goes to the AI provider named on Sub-processors; we keep the feature used and the number of tokens, never the prompt or the answer in the logs. |
4. Why, and on what basis
- Providing AeroViktros to the maintenance organisation - the contract with that organisation; we process staff and customer data on its instructions (GDPR art. 28).
- The organisation's own legal duty to keep maintenance records (Part-145.A.55, CAMO.A.220 / M.A.305) - its basis; we keep what it records.
- Answering a contact or trial request - steps at the person's request before a contract (art. 6(1)(b)) [lawyer: confirm, or legitimate interest art. 6(1)(f)].
- Security of the service: sign-in, rate limits, the audit trail, the sign-in sessions - legitimate interest (art. 6(1)(f)).
- Training, NDT vision exams, occurrence reports and audits - the organisation's own duties under Part-145 (145.A.30, 145.A.35, 145.A.60, 145.A.65) and Reg. (EU) 376/2014. The vision exam is data concerning health (GDPR art. 9): only its date, validity and examiner are kept, [lawyer: Art. 9(2)(b), employment obligations].
- Billing records - legal obligation under the Accounting Act (art. 6(1)(c)).
5. How long it is kept
| What | How long |
|---|---|
| A maintenance organisation's records while it uses AeroViktros | As long as the organisation keeps them. It can export all its records at any time. |
| Records after the organisation's account is suspended | Read-only for 24 months: its administrator can sign in, read and export everything. After that nothing is deleted automatically; the records are deleted only when the organisation asks, after it has downloaded a full export. Maintenance records are kept under a legal obligation (GDPR art. 17(3)(b)): a person's name and authorisation on a record they signed stay on that record. |
| Training records and NDT vision exams | As the maintenance records (insert-only: a correction is a new row). |
| Occurrence reports | [owner/lawyer: period]. A confidential reporter's name is never in the records export; when the person's contact details are removed, their name as a confidential reporter becomes a pseudonym. |
| Audits, findings and CAPA | As the maintenance records (never deleted; CAPA insert-only). |
| Sign-in sessions | 90 days after the session was last used (a daily job). |
| Offline dent & buckle chart: what a device reports (the aircraft kept, how many marks wait and since when, never a mark) | 90 days after the device last reported, or at once when the person is deactivated or their contact details are removed. Except while the device reports damage marks not yet sent: that line (counts and times only) stays until they arrive, as an airworthiness record. A one-time confirmation for sending marks: 1 day after it was used or expired (a daily job). |
| Contact and trial requests | Deleted 12 months after our last contact with the person (a daily job; the log keeps only how many). |
| Technical logs of the platform | 30 days. |
| Billing records | 10 years under the Accounting Act, also after an organisation is deleted. |
| Backups | Deleted data leaves our backups within [owner/lawyer: backup retention days (BACKUP_RETENTION_DAYS)]. |
| Assistant conversations and AI usage | [owner/lawyer: period]. A person whose contact details were removed keeps their conversations only scrubbed of their e-mail, phone and login name; AI usage is kept by the person's number. |
| A records export (ZIP) on our server | Until the next update of the service or 7 days, whichever comes first. |
| A person who left the organisation | The organisation deactivates the account (sign-in ends at once) and can remove the contact details: e-mail, phone, photo and login name are removed, and the audit trail keeps a pseudonym instead of the address. The name, the authorisation and licence numbers and the register history stay on the records the person signed (Part-145.A.55, GDPR art. 17(3)(b)). Free-text comments that mention the person are not changed. |
| The demo | The demo aircraft, work packages and job cards loaded from First steps are not a Part-145 record. An organisation can remove the demo, or archive it: an archived demo is kept for audit integrity and deleted with the organisation. A trial user's erasure follows the deactivate / remove-contact-details path above: contact details removed, the name on signed rows kept. |
On your device
If your organisation allows it, this device keeps the aircraft you chose for offline use — their damage marks and photo thumbnails — for up to 7 days, and any damage you record offline, with its photos (resized, with no location data), until it is sent (the mark's text, without its photos, a day after that). Logging out asks to remove them; signing out on another device does not. Keep a screen lock on the device.
6. Your rights
- Staff and customers of a maintenance organisation: send your request (access, correction, erasure, restriction, objection, a copy) to that organisation - it is the controller. We help it answer, as the DPA says.
- Contact requests and the platform's own accounts: write to office@aeroviktros.com. We answer within one month.
- You can complain to a supervisory authority; in Bulgaria the Commission for Personal Data Protection.
7. Who receives it, and transfers
Only the providers on Sub-processors, each for the purpose written there; the transfer basis of each one is listed there. Our accountant receives the billing records [owner: the accountant]. Before we add a provider we tell the organisations that use AeroViktros. We do not sell data and do not use it for advertising.
8. Changes
When this notice changes, the date on top changes; a change that affects an organisation's data is announced to it first.