Privacy Policy

1. Introduction

AIVIATION LLC ("we," "us") operates WilcoAI (wilcoai.app and the iOS app, bundle ID: app.wilcoai). WilcoAI is a voice-first ATC drill simulator that grades pilot radio readbacks against FAA phraseology. It is a training aid, not a flight tool. We minimize data collection at every tier. This policy covers both the app and the wilcoai.app website. WilcoAI is offered in the United States, and this policy is written to United States law.

2. Data We Collect

This section lists every category of data we collect. For each, we state what it is, why we collect it, and who receives it; Section 6 states how long we keep it.

Device identifier (all tiers): WilcoAI has no account system -- we collect no Apple ID, name, or email. The app uses a device identifier, stored on your device, and sends it with each Daily Challenge and practice request. We use it to apply usage limits (such as the number of attempts per day), to hold your consumable credit balance, and to measure how the app is used so we can improve it. This identifier is not your name, email, or Apple ID, and it is not an advertising identifier; it identifies a device, not a known person. It is stored so that it persists across an app reinstall, which is what keeps the free daily limit from resetting on a delete-and-reinstall. Because it stays the same across sessions, App Store rules treat data we send alongside it as "Linked to You" (see Section 5). We do not use it to track you across other companies' apps or websites.

Cross-device identifier (all tiers): If you use other AIVIATION apps while signed in to iCloud, we use a separate identifier, stored in your private iCloud account and cached on your device, to recognize that the same person is using more than one device. We use it only to avoid counting one person as several people in our usage measurements. It is not a name, email, or Apple ID.

Session audio (all tiers): When you practice, the app records your microphone and sends that audio to our servers, together with the device identifier above and, in a multi-turn session, a session identifier. We use the audio only to transcribe your readback so it can be graded. Amazon Web Services performs the transcription on our behalf (see Sections 3 and 9). We do not retain the audio after it is transcribed. We do not use your voice to identify you, and we do not create or store voiceprints or any other biometric identifier.

Transcripts and grading notes (all tiers): The text of what you said, and the grade and coaching notes our AI produces from it, are recorded in our logs and in the session record we archive when a session ends. We use them to deliver your grade and debrief, to check and improve grading quality, and to investigate abuse and technical faults. Our grading-quality log contains no name, email, Apple ID, or device identifier. It does contain the transcript itself, which will normally include the callsign you spoke -- so if you use a real aircraft registration as your callsign, that registration appears in the transcript, and a registration can be looked up in the public FAA aircraft registry. The archived session record and our operational logs are stored against the device identifier.

Scenario setup details (all tiers): The callsign and aircraft type from your aircraft profile are sent with each session so the simulated controller and the grader can use them. WilcoAI creates a starting profile with an example callsign in aircraft-registration format, which you can change at any time. For a Full Flight scenario, the origin and destination airport identifiers you enter are also sent. Your home base is stored on your device and is not sent to us.

Usage data (all tiers): We record events describing which practice modes and categories you use, how attempts turn out, streak events, paywall views, and whether a purchase succeeded or failed, together with the app version, the device operating-system version, and your subscription tier. We use these to understand how the app is used and to improve it. If you answer the optional "how did you hear about us" question during onboarding, your answer is recorded as one of a fixed set of choices; the question can be skipped, and skipping it records nothing. We do not collect crash reports or other diagnostic data from your device.

Purchase data: If you subscribe or buy scenario credits, we receive from Apple a record that the purchase is active, the identifier of the product you bought, and a transaction identifier for that purchase. We use these to unlock features, to hold your credit balance, and to measure purchases (see Section 4). We do not receive your payment card details or your Apple ID.

Network information: Our servers record the IP address of each request in an access log, together with the time, the route called, and the response status. We use this to operate and secure the service, including rate limiting and abuse investigation.

Data stored on your device and in your iCloud: Your aircraft profiles and practice history are stored on your device. Your Daily Challenge streak is stored both on your device and in your private iCloud account, so it follows you across your own devices; that iCloud copy is in your iCloud account, not on our servers. See Section 11 for what survives deleting the app.

Website data: Our website records limited page-view information, described in Section 8.

What we do not collect: We do not collect your name, email address, or Apple ID. We do not collect location data, contacts, photos, health data, or advertising identifiers, and we do not buy personal information about you from data brokers or other outside sources.

3. AI Features

WilcoAI uses cloud AI for every drill. Amazon Web Services is the only company that processes your audio and transcripts on our behalf. Your audio goes to Amazon Web Services' speech-to-text service, which converts it to text. The resulting text -- not your audio -- then goes to an Anthropic Claude model that Amazon Web Services hosts and runs on its own infrastructure, which generates the simulated controller's transmissions and grades your readback against FAA standard phraseology. End-of-session debriefs use the same hosted model. Anthropic does not receive your audio, your transcripts, or any other data from us. As described in Section 2, we do not retain the audio; the transcript and grading notes are kept only for the periods stated in Section 6.

Grading and simulated controller responses are AI-generated and may contain errors. WilcoAI is a training aid only. Never act on a simulated clearance.

4. Subscriptions

WilcoAI offers Free, First Officer, and Captain tiers, plus single-scenario consumable credits. All purchases are processed by Apple via StoreKit. We receive a record that your subscription or consumable purchase is active, the product identifier, and a transaction identifier, so we can unlock features and hold your credit balance; we do not receive your payment details. Apple's privacy policy applies to subscription processing.

5. App Store Privacy Nutrition Label

WilcoAI's App Store privacy label discloses, across all tiers, the following data, all Linked to You: Audio Data (used for app functionality -- your spoken readback, sent to our provider to transcribe; we do not retain the recording, and the resulting transcript is kept only for the periods described in Section 6); Identifiers (used for app functionality and analytics -- the device identifier described in Section 2, the cross-device identifier that links your activity across your own devices, and the purchase transaction identifier); Product Interaction (used for app functionality and analytics -- which practice modes you use and how attempts turn out); and Purchase History (used for app functionality and analytics -- your subscription and credit purchases). Each is reported as Linked to You because it is sent or recorded alongside a persistent identifier. "Linked to You," in Apple's framework, means associated with an identifier -- here, a device, cross-device, or transaction identifier -- not that we know your name, email, or Apple ID. WilcoAI has no account, so we never learn who you are. This disclosure matches the app's privacy manifest, which declares these same data types as Linked.

6. How Long We Keep Data

Session audio: not retained. Audio is transcribed as you speak and is not written to storage. In an uncommon fallback path, a copy is staged only for as long as the transcription takes and is then deleted; if that deletion ever fails, an automatic rule removes the file within one day.

Transcripts and grading notes: up to 30 days in our operational logs; up to 90 days in our grading-quality log; and up to 90 days in the session record we archive when a session ends. That archived record also contains the scenario setup details for the session.

Live session state: the in-progress session record expires about 6 hours after it is created.

Controller audio: the synthesized controller transmissions generated for your session are kept up to 10 days so the debrief replay works, then deleted automatically. This is the simulator's voice, not yours.

Usage-limit counters: the counters that drive daily limits expire about two days after your last attempt; monthly limit counters expire about 60 days after they are created.

Consumable credit balance: kept until the credits are used. See Section 11 and our Terms for how the balance is held.

Usage and diagnostics data: up to one year.

Server access logs, including IP address: 30 days.

How we set these periods: we keep personal information only as long as we need it for the purposes described in this policy, including to operate and secure the service, to satisfy any legal, accounting, or reporting requirement, to establish or defend legal claims, and to prevent fraud and abuse. In setting a period we consider the amount, nature, and sensitivity of the information, the potential harm from unauthorized use or disclosure, the purpose we process it for and whether we can achieve that purpose another way, and what the law requires. When we no longer need information, we delete it or strip the identifiers from it.

7. How We Share Data

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We disclose it only as follows.

• Service providers. Amazon Web Services hosts our servers and provides the speech-to-text and AI model services described in Section 3. Apple processes your purchases. Each processes data on our behalf, for the purposes described in this policy.
• Professional advisors. Lawyers, accountants, auditors, and insurers, in the course of the services they provide to us.
• Authorities and legal process. Law enforcement, government authorities, and other parties, where we believe in good faith that disclosure is necessary or appropriate to comply with the law or legal process, to enforce our Terms, or to protect the rights, safety, or property of you, us, or others.
• Business transferees. A counterparty, acquirer, successor, or assignee in connection with an actual or prospective merger, acquisition, financing, sale of assets, insolvency, bankruptcy, or receivership, in which personal information may be transferred as a business asset.

8. Tracking and Other Technologies

Our website. wilcoai.app runs a first-party measurement script. It records the page path you viewed, the hostname of the site that referred you, any campaign parameters in the link you followed, and clicks on links out to the App Store. It sets no cookies, writes nothing to your browser's local storage, and creates no identifier for your browser or device. It honors the Do Not Track and Global Privacy Control signals: if your browser sends either one, the script sends nothing at all. We use no third-party analytics services, advertising pixels, or session-replay tools on our site.

Server logs. As stated in Section 2, our servers record the IP address of each request in an access log, kept for 30 days.

In the app. The app contains no third-party advertising or analytics software development kits, and does not use advertising identifiers or the App Tracking Transparency framework, because it does not track you across other companies' apps or websites.

9. Aggregated Data and AI Training

What we do. We create aggregated and de-identified statistics from the data described in Section 2 -- for example, how often a phraseology category is failed across all users -- and use them to improve WilcoAI and to describe our business. We do not attempt to re-identify de-identified data. We do not sell your personal information, and we do not use your audio, transcripts, or grading notes to train AI models.

The AI model. The Anthropic Claude model that generates controller transmissions and grades your readbacks is hosted and run by Amazon Web Services. Amazon Web Services states that inputs to and outputs from that service are never shared with model providers and are never used to train the underlying models. Anthropic does not receive your data.

Speech-to-text. Amazon Web Services, which provides the speech-to-text service that transcribes your readback, stores and uses audio it processes to develop and improve that service. This is separate from the AI model described above and is that provider's own use of the audio, not ours.

10. Security

We use technical and organizational safeguards designed to protect the data we hold, including encryption of data in transit and at rest, restricted administrative access to our systems, and short retention periods. No method of transmission or storage is completely secure, and we cannot guarantee the security of your information.

11. Your Rights and Data Deletion

On-device data: your aircraft profiles and practice history are stored on your device, and deleting the app removes them.

Data that survives deleting the app: your Daily Challenge streak is also stored in your private iCloud account, and the device identifier and the cached copy of the cross-device identifier are stored so that they persist across an app reinstall. Deleting the app does not remove any of these. The iCloud copy of your streak sits in your own iCloud account rather than on our servers; you can remove it through your device's iCloud storage settings. To clear the stored identifiers, follow your device's instructions for resetting app or keychain data, or contact us at the address below.

Server-side data: we keep the device identifier with usage-limit counters, your consumable credit balance, the archived session record, and our logs, for the periods stated in Section 6. This data is not tied to your name, email, or Apple ID, so we cannot connect it to your real-world identity on our own.

Exercising your rights: you can ask us to tell you what we hold about you, give you a copy of it, correct it, or delete it, and you can appeal if we say no. To make a request, email privacy@aiviation.dev. Because WilcoAI has no account, we cannot locate your records from an email address alone, and we will tell you what information we need in order to find them and confirm they are yours. If you have made a purchase, the transaction identifier shown in your Apple purchase history helps us locate the records associated with that purchase. Where we cannot verify that records belong to you, we may be unable to act on the request, as state privacy laws permit; we will tell you if that happens and why. We will not treat you differently for exercising any of these rights.

Usage analytics: the usage data described in Section 2 is collected on every tier, and WilcoAI does not currently offer an in-app switch to turn it off. Deleting the app stops new events being generated on that device, but it does not reset the device identifier, which is stored so that it persists across a reinstall.

What expires on its own: whether or not you make a request, the periods in Section 6 apply automatically. Deleting the app stops any further collection.

12. U.S. State Privacy Rights

This section applies to residents of U.S. states with a consumer privacy law that gives them the rights below, including California (CCPA as amended by the CPRA), Virginia, Colorado, Connecticut, Utah, and Nevada. Not every right is available in every state.

Categories we collect. Using the categories named in the California statute, we collect: identifiers (the device, cross-device, and transaction identifiers described in Section 2); commercial information (your subscription and credit purchases); internet or other electronic network activity information (your use of practice modes and app screens, and your IP address); and audio information (your spoken readback and its transcript). We collect these from you and from your device, for the purposes stated in Section 2, and we disclose them for a business purpose to the categories of recipients listed in Section 7. We do not collect personal information from data brokers or other outside sources.

Sale, sharing, targeted advertising, and profiling. We do not sell your personal information, we do not share it for cross-context behavioral advertising or targeted advertising, and we do not use it for profiling that produces legal or similarly significant effects. Because we do not do these things, there is nothing to opt out of; we honor the Global Privacy Control signal on our website regardless.

Sensitive personal information. We do not process sensitive personal information for the purpose of inferring characteristics about you. We do not use your voice for biometric identification.

Your rights. Subject to your state's law, you may: know what personal information we collect, use, and disclose, and the categories of sources and recipients; access a copy of it; correct inaccurate information; delete it; obtain it in a portable form; and appeal a decision declining a request.

How to make a request. Email privacy@aiviation.dev, or write to us at the postal address in Section 17. WilcoAI is offered only online and we have a direct relationship with you, so email is our designated request method. We will confirm receipt and respond within the time your state's law allows. Because there is no account, verification works as described in Section 11.

Appeals. If we decline a request, you may appeal by replying to our decision or emailing privacy@aiviation.dev with "Appeal" in the subject line. We will respond in writing with our decision and the reasons for it, and will tell you how to contact your state attorney general if you disagree.

Authorized agents. You may use an authorized agent to make a request. We may ask the agent for proof of authority, such as a signed permission or a power of attorney, and may ask you to confirm directly that you authorized the request.

California Shine the Light. Under California Civil Code section 1798.83, California residents may ask us for the categories of personal information we disclosed to third parties for those third parties' direct marketing purposes in the prior calendar year. We do not disclose personal information for third-party direct marketing. To make a request, email privacy@aiviation.dev with "Shine the Light Request" in the subject line.

Nevada. Nevada residents may direct us not to sell certain personal information covered by NRS Chapter 603A. We do not sell personal information. Our designated address for these requests is privacy@aiviation.dev.

Residents of other states may have similar rights. Contact us at the address above and we will tell you what is available to you.

13. Children's Privacy

WilcoAI is not directed to anyone under 16, and we do not knowingly collect personal information from anyone under 16. If we learn that we have collected personal information from someone under 16, we will delete it. If you believe a child under 16 has provided us personal information, contact privacy@aiviation.dev.

14. Other Sites and Services

The app and our website link to services we do not operate, including the App Store and the FAA's publications. We do not control those services and are not responsible for their privacy practices. Read their privacy policies before using them.

15. International Data Transfer

We are located in the United States and process and store data there. WilcoAI is offered in the United States. If you access it from elsewhere, your information will be transferred to and processed in the United States, where privacy laws may differ from those where you live.

16. Changes to This Policy

We may update this policy. Changes will be posted here with a new effective date, and we will note material changes in the app. Continued use after the new effective date constitutes acceptance.

17. Contact