FlyRecap Privacy Policy

Effective date and last updated September 18, 2026

This Privacy Policy explains how FlyRecap LLC collects, uses, discloses, retains, and protects personal information when you use the FlyRecap application, website, accounts, subscriptions, and related services.

FlyRecap is designed around private flight-training reflection and controlled student-instructor sharing. We do not sell personal information, use it for cross-context behavioral advertising, or use voice recordings to create biometric voiceprints. Because recordings, transcripts, and training information can be sensitive, review the sharing controls carefully and record other people only with legally required permission.

Contents

1 Scope and Controller

This Policy applies to the FlyRecap mobile application, FlyRecap website, support, and related services (collectively, the Service). It applies to Students, CFIs, prospective users, and website visitors. It does not apply to third-party sites, services, flight schools, instructors, or organizations that process information under their own policies.

The Service is offered only to individuals located in the United States who are participating in or supporting U.S.-based flight training. It is not offered or directed to individuals outside the United States.

FlyRecap LLC is the controller or business responsible for the personal information described in this Policy, except when another party independently determines how it will use information it receives from you. FlyRecap is organized in Minnesota and may be contacted using Section 21.

This Policy is a disclosure of our practices and does not waive or limit rights that cannot be waived under applicable law. The Terms of Use govern use of the Service.

2 Information We Collect

2.1 Account and Profile Information

We collect the information needed to create, authenticate, and administer your Account, including account role, age or age range where needed, and account status. Profile photos are stored privately and displayed only as the Service permits, such as to the user and Connected Users. If the Service lets a CFI enter certificate information, FlyRecap does not represent that the information is verified unless the interface expressly says so.

Passwords are managed by our authentication provider and are not available to FlyRecap in readable form. We may collect an authentication identifier or token needed to keep you signed in and secure the Account.

For a user age 16 or 17, the Account may remain pending or restricted until a parent or legal guardian completes FlyRecap's approval process. We may collect the guardian's name, email address, relationship to the user, approval or decline response, typed electronic signature, timestamps, and the versions of the Terms of Use, Privacy Policy, and consent form presented. We use this information to administer eligibility, document approval or withdrawal, activate or restrict the Account, and respond to support, privacy, security, or legal requests. Guardian approval information is not displayed to CFIs or other Connected Users.

2.2 Training and User Content

We collect information you enter, upload, record, import, receive, or create through the Service. Training content is not an official pilot logbook and should not be your only copy of required records, endorsements, or authorizations.

A Connected User may provide information about you, including instructor feedback, skill status, lesson observations, voice notes, and text. We associate that content with the submitting user and the intended student or lesson.

2.3 Information We Do Not Intend to Collect

FlyRecap does not need Social Security numbers, financial account credentials, medical records, health insurance information, or precise real-time location for its core features. Please do not include those items in recordings, notes, photos, or support messages. If a recording incidentally contains sensitive information, it will be handled as User Content under this Policy, but you remain responsible for having authority to provide it.

FlyRecap does not use audio to create a voiceprint, identify a person by vocal characteristics, or authenticate an Account biometrically. Ordinary audio files and transcripts may still be personal information even though they are not used as biometric identifiers.

3 Sources of Information

• From you. Registration, profile, permissions, recordings, imports, notes, training responses, milestones, support, and privacy requests.

• From a parent or legal guardian. Contact, relationship, approval or decline, electronic-signature, and consent-record information submitted through the minor approval process.

• From Connected Users. Invitations, CFI feedback, voice or text messages, shared training information, reports, and connection changes.

• Automatically. Technical, usage, authentication, security, crash, and diagnostic events generated when the Service is used.

• From platforms and providers. Subscription entitlements and limited transaction data from Apple, RevenueCat, or another billing provider; authentication and system events from our infrastructure providers.

• Created by FlyRecap. Transcripts, summaries, milestone determinations, progress patterns, handoff summaries, and other outputs generated from the information above.

4 How We Use Information

We use personal information for the following purposes:

• create, authenticate, maintain, and secure Accounts;

• determine age-based eligibility, send and administer parent/guardian approval requests, document approval or withdrawal, and activate or restrict Accounts for users age 16 or 17;

• provide recording, import, transcription, recap, reflection, milestone, progress, connection, handoff, feedback, notification, export, and subscription features;

• display information to Connected Users as directed by the applicable connection or sharing feature;

• process purchases, verify entitlements, restore purchases, and administer paid access;

• communicate about security, account activity, feedback, connections, feature events, updates, and support;

• personalize the Service using your training stage, preferences, and activity;

• detect, investigate, and prevent fraud, abuse, unauthorized access, unlawful recording, and security incidents;

• debug, maintain, analyze, and improve reliability, usability, accessibility, and product performance;

• enforce the Terms of Use and protect FlyRecap, users, and others;

• comply with law, legal process, tax, accounting, and regulatory obligations; and

• create aggregate or deidentified information for analytics and product improvement, provided we do not attempt to reidentify it except to test our deidentification methods or as permitted by law.

Where applicable law requires a legal basis, we rely on performance of our contract with you, legitimate interests in operating and securing the Service, compliance with legal obligations, and consent for optional processing such as microphone access or AI processing where required.

5 Audio Transcription and Artificial Intelligence

When you use an audio, transcription, or AI-assisted feature, FlyRecap may collect or receive the audio or text and send the portion needed to a transcription or AI provider. The provider processes it on FlyRecap's behalf to return a transcript, summary, category, training insight, or other requested output.

Before personal information is sent to a third-party AI provider, FlyRecap will provide an in-app notice and obtain permission where required. If you decline microphone or AI processing permission, you may use any manual text alternative the Service makes available, but audio or automated features may not function.

We use business or API services and do not authorize providers to use FlyRecap Service Content to train their general-purpose models unless you separately and expressly opt in. Providers may retain limited content or metadata for security, abuse prevention, or legal compliance under their business terms. Authorized personnel may access content only when reasonably necessary for support, security, legal compliance, or quality control subject to confidentiality obligations.

AI and transcription outputs may be wrong. They do not determine legal rights or make decisions about solo eligibility, certification, checkride readiness, endorsements, employment, insurance, credit, housing, or another legal or similarly significant matter.

6 Student CFI Connections and Sharing

FlyRecap uses a controlled connection model rather than public profiles or public posting. The exact information visible to a Connected User depends on the current feature and the choices shown in the Service.

Removing a connection or revoking access stops future access as supported by the Service. It does not erase information a recipient already saw, exported, copied, or lawfully retained outside FlyRecap. Users must not redistribute another person's private training content without authority.

7 Progress Handoffs Milestones and Inferences

FlyRecap may analyze lesson content, transcripts, CFI feedback, user-selected skill statuses, and activity to create progress observations, milestones, trends, suggested focus areas, or a continuity summary. Some milestones are created automatically from objective app events, while others are entered or confirmed by a user.

These outputs are inferences and organizational aids, not official evaluations. A label such as Meets ACS Standard reflects the input or criteria used in the Service and does not itself establish compliance with an Airman Certification Standard, legal proficiency, solo eligibility, endorsement, or checkride readiness.

We do not use these inferences for targeted advertising or for decisions producing legal or similarly significant effects. You may correct the underlying information, and some generated outputs may change when the source data changes.

8 How We Disclose Information

We may disclose personal information in the following circumstances:

• At your direction. To Connected Users or other recipients when you use a sharing, connection, export, or communication feature.

• To service providers. To companies that perform hosting, authentication, private storage, transcription, AI, subscription management, crash reporting, notifications, email, support, security, or similar functions for FlyRecap.

• For safety and integrity. When reasonably necessary to detect or respond to fraud, abuse, security threats, unlawful activity, violations of our Terms, or danger to a person.

• For legal reasons. To comply with law, subpoena, court order, regulatory request, or other valid process; protect legal rights; or establish, exercise, or defend claims.

• In a business transaction. In connection with due diligence, financing, merger, acquisition, reorganization, bankruptcy, receivership, or sale of assets, subject to confidentiality and applicable notice obligations.

• With professional advisers. To attorneys, accountants, auditors, insurers, and similar advisers bound by duties of confidentiality.

• In aggregate or deidentified form. For product, research, business, or reporting purposes where the information cannot reasonably be linked to an individual.

We do not make private lesson content public. We may disclose information to a flight school, employer, or organization only when the user directs the disclosure, the organization is a Connected User or account administrator under a clearly identified feature, or disclosure is otherwise lawful.

9 Service Providers

Providers used by FlyRecap may include:

• Supabase for authentication, databases, backend services, and private file storage;

• OpenAI or another disclosed AI or transcription provider for transcription, summarization, categorization, and related AI-assisted features;

• RevenueCat for subscription entitlement and purchase-management services;

• Apple for App Store distribution, purchases, billing, subscription administration, and platform services; and

• Infrastructure and operations providers for email, notifications, analytics, crash reporting, customer support, security, and hosting as the Service develops.

Providers receive only the information reasonably necessary for their functions and are required by contract or applicable terms to protect it and process it for authorized purposes. Providers may process information in the United States or other locations where they or their subprocessors operate. We will update this Policy when a new provider materially changes how personal information is processed.

10 Sale Targeted Advertising and Profiling

FlyRecap does not sell personal information for money or other valuable consideration and does not share personal information for cross-context behavioral advertising as those terms are defined under applicable U.S. state privacy laws. We do not use third-party advertising networks in the Service and do not allow analytics providers to build cross-app or cross-site advertising profiles from FlyRecap data.

FlyRecap does not profile users in furtherance of decisions that produce legal or similarly significant effects. If these practices change, we will update this Policy, provide required notice, and offer required opt-out or consent controls before the new practice begins.

11 Device Permissions Cookies and Similar Technologies

11.1 Microphone Photos and Notifications

FlyRecap requests microphone access only when needed to record audio. It may request camera or photo-library access when you choose to add or change a profile photo or import supported content. It may request notification permission to alert you about account, connection, feedback, subscription, or training events. You can change these permissions in device settings, but disabling them may limit the related feature.

11.2 Cookies SDKs and Diagnostics

The website and app may use essential cookies, local storage, SDKs, and similar technologies for authentication, security, preferences, entitlement verification, diagnostics, and analytics. We do not use these technologies for third-party behavioral advertising. Browser Do Not Track signals do not have a single legal or technical standard; where law requires recognition of a universal opt-out signal, we honor a valid signal for the covered processing. Because we do not sell or share data for targeted advertising, such a signal generally does not change current practices.

12 Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Policy, including providing the Service, maintaining user-directed training history, resolving disputes, protecting security, and satisfying legal, tax, accounting, and contractual obligations. Retention depends on the type of information, your settings, whether the Account remains active, and legal or technical requirements.

Local cached copies may exist on a device to support playback or performance. FlyRecap is designed to clear protected audio caches at sign-out and Account deletion, but exported files, device backups, and copies outside FlyRecap remain under the control of the device owner or third party.

13 Account Deletion and Content Deletion

You may initiate Account deletion through the in-app deletion control, currently located in Settings under Legal and Privacy, or by contacting hello@flyrecap.com. We begin processing verified deletion requests promptly and ordinarily complete deletion from active systems within 30 days, unless additional time or retention is reasonably necessary and permitted by law.

Account deletion is intended to remove or deidentify the Account, profile, owned training content, stored audio, transcripts, connections, and related personal information from active systems. Some information may remain when:

• a recipient already received or exported it;

• it forms part of another user's independent record and law permits retention, in which case we may remove your identifiers or restrict further use;

• it is held in a restricted backup awaiting overwrite;

• retention is necessary for security, fraud prevention, tax, accounting, legal process, dispute resolution, or enforcement; or

• the information is aggregated or deidentified so it is no longer reasonably linked to you.

Deleting a FlyRecap Account does not cancel an App Store or other externally billed subscription. Cancel the subscription separately through the billing provider. Deleting the app from a device does not delete the Account.

14 Your Privacy Rights and Choices

Depending on where you live and subject to legal exceptions, you may have the right to:

• confirm whether we process personal information and access categories or copies of it;

• correct inaccurate personal information;

• delete personal information;

• obtain information you provided in a portable format where technically feasible;

• obtain a list of specific third parties to which personal information was disclosed where applicable law requires it;

• opt out of sale, targeted advertising, or qualifying profiling;

• withdraw consent for future optional processing;

• appeal a refusal to act on a request; and

• exercise rights without unlawful discrimination or retaliation.

Use available in-app settings or email hello@flyrecap.com with the subject Privacy Request. Identify the right you want to exercise and the Account email. We may verify identity using information already associated with the Account and may deny or limit a request where we cannot verify it or an exception applies. An authorized agent may submit a request where law permits, subject to proof of authority and identity verification.

For a user age 16 or 17, a parent or legal guardian may also contact hello@flyrecap.com to withdraw approval, request review or correction of guardian approval information, or assist with a privacy request, subject to reasonable identity and relationship verification and the teen user's rights under applicable law. Withdrawing approval may require restriction, suspension, or deletion of the teen user's Account, subject to Section 13 and permitted retention.

Where applicable, we respond within 45 days and may extend once when reasonably necessary after providing notice. Requests are generally free, although law may allow a reasonable charge or denial for manifestly unfounded, excessive, or repetitive requests.

To appeal, email hello@flyrecap.com with the subject Privacy Appeal within a reasonable period after our response. Include the original request and why you believe the decision should change. We will respond within the period required by applicable law and explain how to contact the appropriate regulator or state attorney general if the appeal is denied.

15 U S State Privacy Disclosures

U.S. state privacy laws apply only when their scope and thresholds are met. FlyRecap may voluntarily honor reasonable access, correction, deletion, and portability requests even when a particular law does not require it.

For Minnesota residents, the Minnesota Consumer Data Privacy Act provides qualifying consumers with rights that may include access to categories, correction, deletion, portability, opt-out rights, information about qualifying profiling, and a list of specific third parties. The statute generally applies only after specified processing or revenue thresholds and includes a small-business exclusion, but Section 14 describes how to submit a request regardless.

FlyRecap does not currently sell personal information, share it for cross-context behavioral advertising, use it for targeted advertising, or conduct qualifying profiling. Therefore, there is no current sale, sharing, targeted-advertising, or significant-decision profiling activity to opt out of. If that changes, we will add required controls before beginning the activity.

16 California Notice at Collection

For California residents, the table below summarizes the categories of personal information collected during the preceding 12 months, the purposes, and categories of recipients. We have not sold or shared any category for cross-context behavioral advertising during that period. We do not use or disclose sensitive personal information for purposes that require a right to limit under California law.

California residents may request to know, correct, delete, or obtain a portable copy of qualifying information and may use an authorized agent. We do not discriminate for exercising rights. California Shine the Light: we do not disclose personal information to third parties for their own direct marketing purposes.

17 Children and Teen Users

FlyRecap is intended only for users age 16 and older. Users under 16 may not create or use a FlyRecap Account. We do not knowingly permit or maintain Accounts for users under 16. If we learn that an under-16 user created an Account or that we collected personal information from such a user contrary to this Policy, we will take reasonable steps to restrict or deactivate the Account and delete or deidentify the information as appropriate, subject to limited retention permitted or required by law.

Users age 16 or 17 may use FlyRecap only after a parent or legal guardian completes the approval process provided by the Service. FlyRecap generally uses an age range rather than an exact birth date where the Service allows. Until parent or guardian approval is completed, the Account may remain pending or restricted and may not use recording, training-content, connection, communication, or other protected features.

FlyRecap may send a secure approval request to the parent or legal guardian email provided for a 16- or 17-year-old user. The approval process may request the guardian's name, email address, relationship to the user, required confirmations, typed full name as an electronic signature, and an approval or decline response. We record the response, date and time, and the versions of the Terms of Use, Privacy Policy, and consent form presented so that we can administer and document the authorization.

Parent or guardian approval information is not shown to CFIs or other Connected Users. A parent or legal guardian may withdraw approval by contacting hello@flyrecap.com. Withdrawal may require restriction, suspension, or deletion of the teen user's Account. We may retain limited approval records as described in Section 12 when reasonably necessary for security, dispute resolution, or legal or contractual recordkeeping.

We do not sell or share minors' personal information for targeted advertising and do not use teen data for decisions producing legal or similarly significant effects. If you believe a user under 16 is using FlyRecap, contact us promptly at hello@flyrecap.com.

18 Security

FlyRecap uses administrative, technical, and organizational safeguards designed to protect personal information. Depending on the system, these may include authenticated access, encrypted network transmission, private object storage, access-control and database authorization rules, least-privilege practices, protected secrets, logging, and deletion of local audio caches at sign-out and Account deletion.

No method of transmission or storage is completely secure. You are responsible for protecting your credentials and device, installing updates, reviewing recipients before sharing, and keeping exports secure. Notify us promptly at hello@flyrecap.com if you suspect unauthorized access or disclosure.

19 United States Only Service

FlyRecap is based in the United States and is intended solely for individuals located in the United States who are participating in or supporting U.S.-based flight training. FlyRecap is not offered or directed to individuals outside the United States.

Personal information is primarily processed in the United States. Certain service providers or their personnel may process information from other locations where they operate, subject to their contractual confidentiality, security, and data-protection obligations.

If FlyRecap expands outside the United States, we will update this Policy and implement any additional notices, contractual safeguards, representatives, consent mechanisms, or other measures required before offering the Service in those locations.

20 Changes to This Policy

We may update this Policy as the Service, providers, or law changes. We will post the updated Policy and revise the date above. If a change materially affects how we use previously collected personal information, we will provide additional notice and obtain consent where required before applying the change. We encourage you to review the Policy when the Service changes.

21 Contact Us

Questions, privacy requests, appeals, parental requests, or complaints may be sent to:

FlyRecap LLC
11575 E Laketowne Dr
Albertville, MN 55301-4348
United States
hello@flyrecap.com