Privacy policy
In force from 9 October 2026 (this version replaces the one in force from 17 September 2026). Last updated: 17 October 2026.
Who we are
We don’t have a data protection officer and aren’t required to appoint one. For anything about your data, email info@towertalk.co.uk.
What we collect, why, and our legal basis
UK data-protection law says we must have a lawful basis for each use of your data. This table sets out each purpose, what data it uses, the basis we rely on, and who else receives the data. We do not sell your data.
| What we collect | Why | Legal basis | Who receives it |
|---|---|---|---|
| Account data: name, email address, login details (or your Google sign-in), and your edition (UK or US). | To create and run your account and let you sign in. | Contract: we need it to give you the service you asked for. | Supabase (stores it and runs login); Google if you choose Sign in with Google. |
| Training data: practice sessions, scores, verdicts, radio-call transcripts, the controller conversation, feedback, progress, saved routes, aircraft and settings, and a profile picture if you upload one. If you take the Radio Readiness Check while signed in, we also keep its result: the score, the one-line summary and the points the marker said were missing. Checks taken while signed out are not stored. | To run the exercises, mark your calls, show your progress and keep your history. | Contract. | Supabase; OpenAI and Anthropic for the AI replies and marking (see Voice and AI below). |
| Voice: the spoken radio call you make. | To turn your speech into text and mark it. | Contract: it is the feature you are using. | OpenAI (transcription). The transcript then goes to OpenAI and Anthropic. We do not keep the audio. |
| Payment data: what you bought, the plan, renewal and cancellation status. Card details are handled by Stripe and we never see them. | To take payment, give you the access you bought, and keep the records the law requires. | Contract; legal obligation for accounting and tax records. | Stripe. |
| Service emails: account confirmation, password resets, bookings, invitations, receipts and notice that paid access is ending. We record which of these we sent and when. | So the service works and you know what is happening to your account. | Contract, and our legitimate interest in running the service. | Resend (sends the email). |
| Marketing email, and the record of your consent: whether you opted in, when, where, and the wording you saw. | To send training tips, product news and offers, only if you opt in. | Consent. You can withdraw it at any time. | Resend. |
| Sign-up check: signals from your browser and connection that show you are a person. | To stop automated sign-ups. | Legitimate interests (security and preventing abuse). | Cloudflare (Turnstile). |
| A random device ID in a cookie, and request counts. | To apply fair-use limits to AI features, including for visitors who are not signed in. | Legitimate interests (preventing abuse and runaway cost). | Vercel and Supabase (hosting and database). |
| Your country, reduced to “UK/EEA” or “elsewhere” in a cookie. | To show the cookie banner your local law expects. | Legal obligation and legitimate interests. | Vercel tells us your country; we keep only the two-way answer. |
| Analytics: our own usage counts (event, page path, web or app, edition, a random visitor ID, and your account if signed in), where you first came from, and Google Analytics and the Google Ads tag. | To see which pages and exercises help people learn and which marketing channels work. | Consent in the UK and EEA, where we ask first. Elsewhere we give notice and an opt-out, relying on legitimate interests. | Supabase for our own counts; Google for Google Analytics and the Ads tag. |
| Messages and feedback you send us (contact form, in-app feedback, the help assistant), with the email address you give. | To reply, fix problems and improve the service. | Legitimate interests; contract if you are a customer. | Supabase; Resend for replies; OpenAI for the help assistant’s answers. |
| Reports you make about content or behaviour, and anything you attach. | To meet our duties under the Online Safety Act 2023 and these terms. | Legal obligation. | Our staff; the National Crime Agency or police where the law requires. |
| If you train with a school or instructor: your link to them and, if they record it, your date of birth (to complete the CAA’s SRG1171 form), the completed form and documents they add to your training record, bookings, lesson reports and invoices. | So they can teach you, keep your training record and run their business with you. | Contract with you and the school’s own legitimate interests; see “If you train with a school or tutor” below. | Supabase; Daily for live lessons; Resend for notices. |
| Training-record checks: when you or your school make a training-record PDF, we keep a short record so the PDF can be checked later. It holds the verification code in scrambled form only, a fingerprint of the PDF file, your name, the school’s name, the dates the record covers and when it was made. It holds no scores. | So anyone you give the PDF to, such as a school or examiner, can confirm at our verification page that it is genuine and has not been altered. | Legitimate interests: yours and theirs in being able to trust the record, and ours in preventing altered records. | Supabase. The verification page shows only the name, school, dates and whether the PDF matches. |
| Examiners only: recordings made with the FRTOL practical-test recording tool, with the candidate name and reference. | So a verified examiner can make and keep a record of a test. | Legitimate interests of the examiner and TowerTalk in providing the tool. | Supabase (private storage). No AI processes these recordings. |
| Logs needed to run, secure and fix the service. | To keep the service working and secure. | Legitimate interests. | Vercel and Supabase. |
Voice and AI
- When you speak a radio call, your browser records it and sends it to our server, which passes it to OpenAI to be transcribed. We do not store the audio: it is not written to our database or storage.
- The transcript, your scores and the feedback are stored in your training history until you delete them or your account.
- The transcript and the conversation with the AI controller are sent to OpenAI and Anthropic to write the controller’s replies and to mark your call, along with context such as your callsign, aircraft type and airfield. Anthropic reviews the controller’s draft reply before you see it, and answers instead if OpenAI is unavailable.
- Before what you type or say reaches the AI, it is checked automatically by OpenAI’s moderation service, to keep the conversation on flying and to stop harmful content. If something is flagged, it is not sent on. We keep only a count of how often this happens, by screen and type, never the text itself or who sent it.
- The controller’s spoken replies are produced by sending the controller’s text (not your voice) to OpenAI.
- If you use the help assistant, what you type is sent to OpenAI to write the answer.
- The one exception to “audio not kept”: verified examiners can use a practical-test recording tool. It stores the recording in private storage, where only that examiner can open it. The CAA requires examiners to keep test recordings (at least 45 days, and the examiner’s five most recent for at least five years), so the tool lets an examiner delete a recording only once that period has passed. Deleting an examiner account removes its recordings. No AI processes those recordings.
- Live lessons are not recorded by TowerTalk, and the lesson room is set so that recording is not available in it. We do not transcribe lessons. If an instructor records a lesson by other means and pastes a link into their lesson report, we hold that link only; we do not fetch or process the recording. Each person is told this before joining.
Our AI providers process this data for us under their own terms, including how long they keep it.
Automated decisions
Who we share it with
We use these companies to run TowerTalk. They act on our instructions and are bound by their terms with us. Here is what each receives:
- Supabase: our database, file storage and login. Holds the data described in this policy.
- OpenAI: audio of your calls (for transcription), transcripts and context for AI replies and marking, the controller’s text for speech, and help-assistant messages.
- Anthropic: transcripts and the controller conversation for AI replies and marking.
- Stripe: your name, email and payment details when you pay, and your subscription or pass status.
- Resend: your email address and the content of the emails we send you, and delivery events.
- Daily: the live video and audio of lesson and voice rooms you join.
- Cloudflare: signals from your browser and connection for the sign-up check.
- Google: your sign-in, if you choose Sign in with Google; analytics and advertising-measurement data only if you allow it (or, outside the UK and EEA, do not opt out).
- Vercel: our hosting provider, which handles requests to our site, including your IP address.
We may also disclose data to professional advisers, to authorities where the law requires, or to a buyer if the business is sold. We do not sell or rent your email address, share it with other advertisers, or use it to build advertising profiles on other platforms.
If you train with a school or tutor
When you join a school or instructor on TowerTalk, they can see your training work so they can teach you: your practice sessions, scores and phraseology history. Radio debriefs stay private unless you share them individually. A school can also record your date of birth to complete the CAA’s SRG1171 form, file the completed form and other documents in your training record, and keep bookings, lesson reports and invoices. Those documents are visible only to you and your school.
Two limits worth knowing. If you book a tutor yourself through our public directory, they see only the work you do from the date you booked them onwards, not your whole history, unless you choose to share it. And a school may bring in a covering instructor to teach you; that instructor can see your training history for as long as they are teaching you, on the school's behalf.
When you join a school you choose whether it can see your training from before you joined; if you don't, it sees only your work from the date you joined. If you leave, or either of you ends the link, the school keeps a read-only view of your training up to the date the link ended, and nothing after it. Your school can make a PDF or spreadsheet of your training record for its own files, with the same limits. A school may also invite you using details from its own training-management system, and, if it connects that system to TowerTalk, receive the same record there, with the same limits and never your call transcripts or audio.
A school or instructor decides what they record about you and why, and under our terms they must have the authority and any consents needed to add you. You can see which schools or instructors you are linked to in your account, and ask us to remove a link at any time. To exercise your rights over what a school holds, ask the school; you can also contact us and we will pass your request on.
International transfers
How long we keep it
Where we have not set an automatic deletion date, we say so rather than give a period we do not apply.
| Data | How long |
|---|---|
| Account, profile, settings, training history (sessions, transcripts, conversation logs, voice scores, progress, debriefs), saved routes, aircraft | Until you delete them or delete your account. We do not currently delete inactive accounts automatically. You can delete your training history alone, or the whole account, from your account page. |
| Audio of your calls | Not stored by us. It exists only while your call is being transcribed. |
| Profile picture | Until you replace or remove it, or delete your account, when it is removed from our storage. |
| Examiner practical-test recordings (examiners only) | Kept for the period the CAA requires of examiners: at least 45 days, and the examiner’s five most recent for at least five years. An examiner can delete a recording only after that. Deleting the examiner’s account removes the recordings. |
| Anonymous training statistics | Kept without a time limit. When you delete your account, your practice sessions are kept as scores by exercise, with no name, email or account number, no exact times, and a random grouping value made at that moment and stored nowhere else. They cannot be traced back to you. |
| Payment records | Stripe keeps payment records as required by law. Our subscription record is deleted with your account. We keep records we are required by tax law to keep for as long as that law requires. |
| Unsubscribe list | Kept without a time limit. If you unsubscribe, your email address stays on it so we never email you again. Your other consent and email records are deleted with your account. |
| Messages and feedback you sent us | We have not set an automatic deletion date. When you delete your account, your account is unlinked from them, but the name and email address you typed into a message stay in it. Ask us to delete a message and we will. |
| Reports and our decisions | Three years from closure. |
| Our own usage counts | We have not set an automatic deletion date. When you delete your account, your account is unlinked from your events; the random visitor ID in them stays, and cannot identify you without the device itself. |
| Records and documents a school or instructor holds about you (student record, date of birth, SRG1171 form, documents, bookings, lesson reports, invoices) | Held for the school, not by your own account. Deleting your account unlinks you from the school’s student record but does not delete the record or its documents. Ask your school, or contact us and we will pass your request to them. |
| A school’s view of your training after you leave | Read-only, and only up to the date the link with the school ended. Nothing you do after that date is shared with that school. Deleting your account removes your own training history, so the school can no longer see it. |
| Training-record check records (name, school, dates, PDF fingerprint) | Kept after you delete your account, so a PDF you have already given to someone can still be checked. Your account is unlinked from them. Ask us to delete one and we will; that PDF will then no longer verify. |
| Cookies and browser storage | Each has its own lifetime, listed on our cookie policy. |
| Copies held by our providers | Our providers keep data for the periods in their own terms, including in backups for a limited time after deletion. |
Step-by-step instructions, and what is kept afterwards, are on our delete your account page. Deleting your account also cancels any subscription you hold, straight away.
Emails we send
We send two different kinds of email, and they follow different rules.
- Service (transactional) email: things you need in order to use what you’ve asked for, such as account confirmation and password resets, lesson bookings and changes, invitations you or your instructor triggered, receipts, and notice that paid access is about to end. You can’t unsubscribe from these while you hold an account, because without them the service doesn’t work.
- Marketing email: optional nudges, training tips, product news and offers. These are opt-in only. The box is never pre-ticked, and if you don’t tick it you will never receive one. Our sending code checks your consent on every marketing send, so withdrawing consent takes effect immediately.
Withdrawing consent. Every marketing email carries a one-click unsubscribe link that works without logging in. You can also turn marketing email off in your account settings, or email us. Unsubscribing adds your address to a suppression list and invalidates the link you used. Withdrawing consent doesn’t affect the lawfulness of anything we sent beforehand, and doesn’t stop service email.
Cookies and local storage
What you have to give us, and what is optional
To have an account you need an email address (or Google sign-in) and a password: without them we can’t create one. To buy a plan you have to give Stripe your payment details. The age check needs your date of birth, which stays in your browser. Everything else — your aircraft, home airfield, profile photo, voice recordings — is optional: you can type your radio calls instead of speaking them, and the service still works without the rest. None of this is required by law; it is what we need to provide the service you asked for.
Do Not Track. We don’t currently respond to “Do Not Track” browser signals. Analytics and advertising measurement run only if you accept them in the cookie banner, which you can change at any time on the cookie policy page.
Your rights
Under UK GDPR you have the right to be told how your data is used (this policy), and to:
- access the data we hold about you;
- correct data that is wrong;
- delete your data;
- restrict how we use it;
- take it with you (data portability);
- object to uses based on our legitimate interests, and to direct marketing;
- withdraw consent at any time, where we rely on it; and
- ask that a person looks again at an automated decision about you.
Tools in your account. Under Account, in Data & privacy, you can:
- Export my data: downloads one file of the records we hold about you: your profile and settings, aircraft and airfields, saved routes, practice sessions, conversation logs, progress, voice assessments, subscriptions and the purchase consents you gave, messages you sent us, your notifications, usage records, and the school records kept about you as a student. Three kinds of record are not in it: records that also identify other people (such as a lesson shared with other students), our internal staff and audit logs, and lesson reports and invoices your school holds, which the school can give you. Email us if you want a copy of any of those.
- Delete training history: removes your conversation logs, voice assessments, phraseology history, practice sessions and progress, and keeps your login.
- Delete my account: described above.
For anything else, email info@towertalk.co.uk. We may ask you to confirm it is your account, and we reply within one month, which is the time UK law allows. There is no charge, except where a request is clearly unfounded or excessive.
Your rights by country
- UK / EU / EEA: under UK & EU GDPR you can access, correct, delete, restrict, port or object to processing, and complain to your supervisory authority (in the UK, the ICO).
- California (US): under the CCPA/CPRA you can know, delete, correct and opt out of “sale”/“sharing” of personal information; we don’t sell your data.
- Other countries: you keep any data-protection rights granted by your local law, which we honour where they apply.
Complaints
Children
TowerTalk is for people aged 16 or over, and nobody under 13 may use it on their own. When you sign up we ask for your date of birth to check your age. We work out in your browser whether you are 16 or over; the date is never sent to us or kept. We keep only that you passed the check and when. If you are under 16 we don’t create an account and we keep nothing you entered. If you sign in with Google or an existing account and tell us you are under 16, we sign you out and keep a note on the account, with the time, that it can’t be used for TowerTalk. Accounts that already existed were asked once to confirm they are 16 or over, or joined through a school or instructor, and we keep that confirmation.
Under-16s may use TowerTalk only through a school or instructor, who enrols them by student number or by an email invitation. We don’t ask for a date of birth in that case, though a school may record one to complete the CAA’s SRG1171 form (see above). The school or instructor is responsible for any parental consent needed and for supervising that use; we don’t check consent ourselves. We don’t knowingly collect data from under-16s outside that arrangement. If you think a child has an account, contact us and we will remove it.
In the United States: nobody under 13 may create an account, and we don’t knowingly collect personal information from children under 13 (COPPA). If we learn that we have, we delete it. Where a US school enrols a student under 13, the school provides the consent COPPA allows it to give for educational use, and we use that student’s data only for their training with that school.
