1. Controller
- The controller of the personal data processed in connection with Aeré Club (aereclub.com) is YNS, a sole trader registered in the Polish Central Register and Information on Economic Activity (CEIDG), ul. Dywizjonu AK Jeleń 4, 00-712 Warszawa, Poland, NIP 9512584486, VAT ID PL9512584486, REGON 527170010 ("we", "us"). Aeré Club is our trading name.
- For any data protection matter, write to privacy@aereclub.com or to the postal address above.
- We have not appointed a data protection officer; Article 37 of the GDPR does not require one.
- Terms defined in the Terms of Use have the same meaning in this policy.
2. Scope
- This policy applies to the Website, to the emails we send (deal alerts, service and billing messages, the newsletter, welcome-code emails and confirmations of a cancellation or withdrawal) and to the messages of our Telegram bot.
- It does not apply to other websites, including the external flight search websites that booking links open (section 13).
- The Service is intended for persons aged 18 or over. We do not knowingly collect data of persons under 18. If you believe a minor has given us data, write to privacy@aereclub.com.
3. Personal data we process
3.1 Data you provide
| Data | When it is collected |
|---|---|
| Email address | When you create an Account |
| Password | When you create an Account with an email address and password. Our authentication provider stores it only as a cryptographic hash; we cannot read or recover it. |
| First name, last name and date of birth (passenger details) | In the passenger-details step, required once before the account area can be used. First and last name can be changed in the Account settings; the date of birth only through support (section 10). |
| Home airports; tracked destinations with a month range and an optional maximum price | When you set your travel preferences |
| Chosen language | When you use the Website |
| The content of your messages | When you contact us |
| Email address | When you request a welcome code, without an Account (clause 3.7) |
| Name, email address and, if given, a contract reference, a date and, for a cancellation, its kind and reason | When you cancel or withdraw on our cancellation or withdrawal page, without signing in (clause 3.8) |
- If you sign in with Google, Google provides your email address, name and profile picture, which our authentication provider (Supabase) stores with your sign-in record. We use the name only to pre-fill the passenger details, which become your passenger details only when you confirm them. We do not use the profile picture. Google does not provide your date of birth.
- Providing your email address and passenger details is a condition of the agreement; without them the Account cannot be used. All other data is provided voluntarily.
3.2 Consent records
- We record each acceptance of the Terms, each grant and withdrawal of consent to marketing email, each consent to the Telegram transfer (section 7), each consent to a recurring charge and each request made at checkout that a Membership start during the withdrawal period (clause 5.5 of the Terms). A record holds: what was consented to and whether it was granted or withdrawn; the date and time; the source (signup form, Google sign-in, re-acceptance page, Account settings, checkout, the additional-destinations page, the plan-change page, an unsubscribe link, a spam complaint, the Telegram bot, the welcome-code box, or an administrator acting on your written request); the version of the Terms accepted or, for the Telegram transfer, the version of this policy in force; for a recurring charge or such a request, the version of the sentence shown and the related Stripe checkout or subscription; and your language.
- For consents given on our pages (acceptance of the Terms, opt-in in the Account settings, Google sign-in, consent to a recurring charge, a request that a Membership start during the withdrawal period) the record also holds your IP address and browser user agent, as evidence of the consent. A signup with email and password, a consent given in the Telegram bot and a newsletter consent carried over from the welcome-code box (clause 3.7) carry neither.
- The log is append-only. A withdrawal is recorded as a new entry; existing entries are not altered.
3.3 Email records
- We keep your marketing email preference, the dates of any unsubscribe, spam complaint or hard bounce, your language and a unique token that operates the one-click unsubscribe link.
- For each newsletter issue sent to you we record the address, the language, your plan at the time, whether it was sent, failed or skipped, Resend's message reference, the times it was queued and sent and, on failure, the error reported by Resend, which may include your address.
- Authentication emails are sent from auth.aereclub.com. Other emails are sent from mail.aereclub.com: deal alerts from alerts@, the newsletter from info@, welcome codes from hello@, billing emails and confirmations of a cancellation or withdrawal from members@, and account notices from accounts@.
3.4 Paid Membership
- Card details are entered in Stripe's payment form and never reach our servers. Stripe also asks for your billing address. To open the form, we give Stripe the email address of your Account and an internal account number.
- From Stripe we store: your plan, the number of additional destinations and that the plan is billed through Stripe; Stripe's customer and subscription identifiers; the subscription status and whether it ends at the next renewal; the billing interval, currency, renewal price and the amount of the last payment before tax; the start date, the dates of the current period, the renewal date and, where it applies, the end of the withdrawal period; the billing country determined by Stripe, used for tax and to decide whether the right of withdrawal applies; and, for a discounted subscription, Stripe's reference for the code and, for a partner or personal code, the campaign it belongs to, which is cleared when the subscription is replaced.
- For a founding member we keep the founding number and the Stripe subscription it was given to.
- Card details, the billing address and invoices are held by Stripe, not by us. You manage them on Stripe's billing page.
- For each paid invoice, refund and lost payment dispute of every paying member we record Stripe's identifiers, the amount paid, the amount net of tax, the products, the currency, the time and, where a code was used, its campaign (payment ledger). We use the ledger to settle with Partners (clause 3.10) and to produce a monthly revenue report, which shows totals by month, currency and product and identifies no person.
- For each partner or personal code, our team sees totals only: the number of Memberships bought with it, how many are still paid, and the sum of their current renewal amounts before tax, by currency and billing interval. The count remains with the code after an Account is deleted. A personal code is used once, so its totals relate to one Membership.
- Billing emails (purchase confirmation, yearly renewal reminder, price-change notice, notice before an introductory price ends, notice of a withdrawal received through the withdrawal page, and messages on cancellation, withdrawal, plan change, a failed or unconfirmed payment and a refund) are sent from members@mail.aereclub.com. For each we record its kind, the subscription and amounts concerned, the times it was queued and sent and Resend's reference. The record holds no address; the address is looked up at the time of sending.
- We log the notifications Stripe sends to our system (Stripe's identifiers, the type and the time of arrival), not their content.
3.5 Data collected automatically
- We use no advertising or social-network tags, do not track you across other websites and do not buy data about you.
- We collect automatically only: (a) the cookies and similar browser storage listed in the Cookie Policy, which are strictly necessary or record your own choice, except that during a Google signup after a Partner's link the
fe-oauth-consentcookie also carries the Partner's link name, which is not strictly necessary (clause 3.10); (b) a Partner's link name read from the page address (clause 3.10); (c) server logs kept by our hosting providers (IP address, requested page, time and response), used only to operate and secure the Service; (d) page-view measurement (point 4). - A booking link passes through our server, which redirects you to the external flight search website. We record nothing about it beyond those server logs.
- Page-view measurement. Vercel Web Analytics records each page view: the time, the page address and path, the referring page, the country, region and city derived from the request, the operating system, browser and their versions, the device type and the script version. It writes no cookie or other browser storage. A visit is recognised only by a hash of the request, discarded after 24 hours, so visits are not linked across days; page views are not tied to your Account or your IP address. The page address may include a Partner's link name (clause 3.10). We use the results only as aggregate statistics on which pages are visited and where visitors come from, and send no other events.
3.6 Telegram
- If you connect Telegram, we store only the chat ID of your chat with our bot. Telegram also tells us whether each message was delivered, including when you have blocked the bot. We store no Telegram username, phone number, profile or message history. Sections 6 and 7 describe what Telegram receives.
3.7 Welcome code
- If you request a welcome code (clause 5.9 of the Terms), we keep: your email address and language; the code, its discount, the dates it was sent and expires, whether the reminder was sent and whether, when and by which Account it was used; and a one-way fingerprint of your address, which cannot be turned back into the address, used to issue one code per address and kept with the code after the address is deleted.
- If you tick the newsletter box, we record the consent (that it was given, when, the version of the sentence shown, your language, your IP address and browser user agent) and later its confirmation, an unsubscribe or a spam complaint. These records are kept under the fingerprint, not under the address.
- We send the code and one reminder before it expires. If you ticked the newsletter box, we send one confirmation email; the newsletter starts only if you click its link within 7 days. If your address hard-bounces or a spam complaint is received about it, we send it nothing more and keep a fingerprint of the address to ensure this.
- If you later open an Account with the same address, a confirmed newsletter consent passes to the Account when you confirm the Account's email address, unless you make a different choice for the Account (leaving the marketing box on the signup form unticked counts as one). In either case the address leaves the box's list. The consent log shows a carried-over consent and refers to the box's record.
- To prevent abuse, we count requests per IP address, email address and email domain. Each count is stored under a one-way fingerprint and deleted after two days.
3.8 Cancellation and withdrawal declarations
- When you send a cancellation or a withdrawal on our cancellation or withdrawal page (clauses 5.4 and 5.5 of the Terms), we record: the kind of declaration; your name and email address as typed and, if given, the contract reference, the requested date and, for a cancellation, its kind and reason; the time of receipt, your language and a receipt reference; the IP address and browser user agent of the request, as evidence of receipt; the Account and subscription matched to it, if any, and how it was handled (applied, reviewed by a person, whether the confirmation was sent); and, for a matched withdrawal, when it is due to be carried out and whether and when it was stopped through the link in our notice.
- The record is append-only; only its handling status changes.
- We email a confirmation of receipt to the address typed, from members@mail.aereclub.com. It repeats the content of the declaration and states the time of receipt (UTC) and the receipt reference, but not whether a Membership was found. We do not send it if the address has previously hard-bounced or drawn a spam complaint, or if the same IP address or email address has exceeded our rate limits; the declaration is still recorded and reviewed by a person. On a day with unusually many declarations from addresses that match no Account, we may automatically stop sending these confirmations to unmatched addresses; a person can then send them manually. The confirmation on the page is always shown.
- For a withdrawal sent on the withdrawal page that matches a Membership, we email the address registered on the Membership, not the address typed, which the notice does not show, stating when the withdrawal was received and when it will be carried out, with a link to stop it. We record whether and when the link was used and nothing else about who used it.
- To prevent abuse, we count requests per IP address and email address. Each count is stored under a one-way fingerprint and deleted after two days.
- A withdrawal made by deleting the Account is recorded in the same way, without an IP address or user agent.
3.9 Personal codes
- A personal code (clause 5.10 of the Terms) may be tied to one email address. We then store a one-way fingerprint of that address, not the address itself, and compare it at checkout with the fingerprint of the signed-in Account's address. If they differ, the code is refused.
- With each partner or personal code we keep an internal note on why it was created, and a record of which team member created it and when.
3.10 Partner attribution
- A Partner may refer you by a link (a page address ending in
?ref=and the Partner's link name) or by a partner code entered at checkout, with or without a discount. - A script on the page reads the link name once, removes it from the address bar and holds it only in the memory of the open tab, not in a cookie or other browser storage, except
fe-oauth-consentduring a Google signup. It is lost when you reload or close the tab, and our server does not read it from the address. The script does this for every visitor who opens a Partner's link, without asking for consent. To avoid a record, reload the page before you sign up or pay. - If the tab holds a link name, we record the referral when you sign up with an email address and password, when you sign up with Google, or when you start a paid checkout while signed in. The record holds your Account, the Partner and the time. Only the first record is kept, and it is never changed.
- When your first invoice is paid, we create a record for every paying member holding Stripe's customer identifier, your Account and the first payment with its time. If a Partner counts, the record also holds the Partner, whether by code or by link, and a pseudonym (
#followed by six characters), calculated separately for each Partner with a secret key that Partners never receive. A partner code used at checkout prevails over a link; a link counts only if the first payment is made within 90 days of its record; the Partner must be active at the first payment; a link recorded after the first payment never counts. Otherwise no Partner is recorded. - Before a Partner earns commission, we compare a one-way fingerprint of your email address with that of the Partner's own address, to exclude self-purchases. We calculate the commission on each of your payments, hold it for a period before it becomes payable and reduce it if a payment is refunded or a dispute is lost.
- Each month we send the Partner a statement listing, for each payment on which its commission is based, the pseudonym, date, product, monthly or yearly billing, amount net of tax, rate and commission, with refunds and lost disputes as separate lines. The statement contains no name, email address or other contact detail, and our agreement with each Partner prohibits any attempt to re-identify a member. A Partner who knows that you joined, and roughly when, may nevertheless recognise your pseudonym from the date and amount.
4. Purposes and legal bases
| Purpose | Legal basis (GDPR) |
|---|---|
| Providing the Account and the Service, including matching Deals to your preferences and sending alerts | Contract, Art. 6(1)(b) |
| Taking payments and managing the Membership, including a founding number | Contract, Art. 6(1)(b) |
| Recording your consent to a recurring charge and your request that a Membership start during the withdrawal period | Contract, Art. 6(1)(b); legitimate interest in proving the consent or the request, Art. 6(1)(f) |
| Service messages, including the billing emails in clause 3.4; these are not marketing and cannot be refused while the Account exists | Contract, Art. 6(1)(b) |
| Keeping the record of renewal reminders | Legitimate interest in establishing and defending claims, Art. 6(1)(f) |
| Newsletter and other marketing email, including the birthday email (section 5) | Consent, Art. 6(1)(a) |
| Sending a requested welcome code and its reminder | Steps taken at your request before a contract, Art. 6(1)(b) |
| Sending the newsletter to an address given in the welcome-code box | Consent, Art. 6(1)(a) |
| Keeping consent records, including those of the welcome-code box | Legal obligation, Art. 6(1)(c) with Art. 7(1); legitimate interest in defending claims, Art. 6(1)(f) |
| Fingerprints and request counts for the welcome-code box and the cancellation and withdrawal pages; one welcome code per address | Legitimate interest in preventing abuse, Art. 6(1)(f) |
| Recording the code used for a Membership | Contract, Art. 6(1)(b) |
| Per-code totals for partner and personal codes | Legitimate interest in assessing partnerships and settling with Partners, Art. 6(1)(f) |
| Reading a Partner's link name and recording the referral (clause 3.10) | Legitimate interest in settling with Partners, Art. 6(1)(f). The link name identifies the Partner, not you; it stays in the open tab; nothing is recorded unless you sign up or start a paid checkout in that tab; the record is used only for settlement, and Partners receive no contact details from us. You can avoid the record by reloading the page and can object (section 10). |
| The first-payment record, with the Partner and the pseudonym where a Partner counts | Legitimate interest in settling with Partners, Art. 6(1)(f) |
| The payment ledger, the self-purchase check, the calculation of commissions and the monthly statements sent to Partners | Legitimate interest in settling with Partners, Art. 6(1)(f) |
| Keeping commissions and statements for the period in section 8 | Legal obligation under Polish tax law, Art. 6(1)(c) |
| The monthly revenue report | Legitimate interest in running and planning the business, Art. 6(1)(f) |
| Tying a personal code to the fingerprint of one email address | Legitimate interest in restricting the code to its holder, Art. 6(1)(f) |
| Recording, applying and confirming a cancellation or withdrawal | Legal obligation, Art. 6(1)(c); for a member, also contract, Art. 6(1)(b) |
| The notice to the registered address before a withdrawal from the withdrawal page is carried out, and recording whether it was stopped | Legitimate interest in protecting members from withdrawals they did not send, Art. 6(1)(f); for a member, also contract, Art. 6(1)(b) |
| Keeping cancellation and withdrawal records with the IP address and user agent | Legitimate interest in establishing and defending claims, Art. 6(1)(f) |
| Keeping your name on the Account and greeting you by first name in alerts by email and, under the condition in section 6, on Telegram | Contract, Art. 6(1)(b) |
| Checking from the date of birth that you are 18 or over | Contract, Art. 6(1)(b): verifying capacity to conclude it |
| Age statistics for our team: the number of members in each age band (18-24, 25-34, 35-44, 45-54, 55-64, 65 and over) by plan, and the average age; a group of fewer than 5 members is shown only as "fewer than 5" | Legitimate interest in understanding our membership without examining individuals, Art. 6(1)(f) |
| Operating and securing the Service and investigating faults and abuse | Legitimate interest, Art. 6(1)(f) |
| Keeping invoices and accounting records | Legal obligation, Art. 6(1)(c) |
| Aggregate page-view statistics (clause 3.5) | Legitimate interest in knowing which pages are read and where visitors come from, Art. 6(1)(f). The statistics identify no one, nothing is stored on your device and visits are not linked across days. You can object (section 10). |
| Analytics that would store data on your device, if introduced and you allow it (none is used today; section 6 of the Cookie Policy) | Consent, Art. 6(1)(a) |
- You may object to processing based on legitimate interests (section 10).
- We apply this policy and the GDPR to all users, wherever they live.
5. Marketing email
- Accepting the Terms is required to create an Account. Consent to marketing email is optional and not pre-ticked. The signup box reads: "Send me the best fares, travel ideas and occasional Aeré Club offers by email (unsubscribe anytime)". Marketing email means our newsletter and occasional offers on our own Membership, such as the birthday discount (clause 5.8 of the Terms); we send no marketing for third parties. Deal alerts are part of the Service and are not marketing.
- A marketing opt-in at signup takes effect when you confirm your email address; no separate confirmation is sent. A newsletter request in the welcome-code box takes effect only after you click the confirmation link within 7 days (clause 3.7).
- Every marketing email carries our sending address, a subject that describes its content, our postal address and an unsubscribe link.
- You may withdraw your consent at any time in the Account settings or with one click from any marketing email, without signing in. The withdrawal takes effect immediately and in any event within ten business days. It does not affect the lawfulness of earlier processing or the sending of service messages.
6. Recipients
The following processors handle personal data on our instructions:
| Processor | Service | Where data may be processed |
|---|---|---|
| Supabase | Database and authentication: the Account, passenger details, preferences, consent log, email preferences and the records described in clauses 3.7 to 3.10 | Inside and outside the EEA, including the United States |
| Stripe | Payment form, payments, subscriptions, invoices and the billing page | Inside and outside the EEA, including the United States |
| Vercel | Hosting of the Website and page-view measurement (clause 3.5) | Inside and outside the EEA, including the United States |
| Cloudflare | DNS for our domains and routing of email sent to us | Globally, including the United States |
| Resend | Sending of our emails | The United States (section 7) |
| Hosting of the mailbox that receives email sent to our addresses | Inside and outside the EEA, including the United States |
- We do not sell or rent personal data.
- Stripe also processes some payment data as an independent controller, for example to prevent fraud, under its own privacy policy. If you choose a payment method other than a card in the payment form, such as PayPal or Klarna, its provider processes your data as an independent controller under its own policy. If you sign in with Google, Google acts under its own terms.
- Telegram, if you connect it, receives your chat ID and the text of each alert and of each reply our bot sends you, and processes them as an independent controller under its own policy. Telegram is connected only after the bot shows you the transfer notice described in section 7 and you accept it. Each alert holds the route (two city names), cabin, travel month, fare and currency, a comparison figure, the number of stops, a pricing-error warning where applicable, a link to a destination photograph on our Website, which Telegram's servers fetch, and a link to the Deal. Your first name opens alerts and bot replies only if you connected Telegram after accepting the version of the notice that names it. The chat ID is deleted when you send
/stop, disconnect Telegram in the Account settings or delete the Account. No marketing is sent through Telegram. - The Partner who counts for your Membership (clause 3.10) receives the monthly statements, which identify you only by pseudonym, and uses them as an independent recipient to verify and invoice what we owe it. We treat these statements as personal data, because we can link a pseudonym to an Account. If no Partner counts, no Partner receives anything about you.
- We disclose personal data to courts, supervisory authorities or law enforcement bodies where the law requires it, and where necessary to establish, exercise or defend legal claims.
- If the business is sold or reorganised, personal data may pass to the acquirer. We will inform you before a different privacy policy applies to your data.
7. Transfers outside the EEA
- Resend stores account data, message metadata and logs in the United States, whichever sending region is selected. The email addresses we send to, the first name used in greetings and the related delivery metadata are therefore transferred to the United States.
- The other processors in section 6 are global services whose infrastructure and support extend outside the EEA, including the United States. We treat their processing as involving a transfer.
- Transfers to processors are based on the European Commission's Standard Contractual Clauses incorporated in each provider's data processing agreement and, where the provider is certified, also on the EU-US Data Privacy Framework.
- Telegram operates outside the EEA, and no Standard Contractual Clauses or adequacy decision cover the transfer to it. The transfer is based on your explicit consent under Article 49(1)(a) of the GDPR. Before your chat is connected, the bot shows a notice stating what is transferred (the chat ID, your first name and the content of each alert and reply), that Telegram operates outside the EEA without those safeguards, the possible risks (protection weaker than under the GDPR, access by public authorities, no effective means of enforcing your rights), that declining has no consequence because every alert is also sent by email, and that consent can be withdrawn at any time with
/stopor in the Account settings. Nothing is connected unless you accept. A withdrawal does not affect earlier transfers or messages already held by Telegram. - If the Partner who counts for your Membership is established outside the EEA in a country without an adequacy decision, the statements are transferred under the Standard Contractual Clauses for transfers between controllers included in our agreement with that Partner.
- A copy of the safeguards is available on request at privacy@aereclub.com.
8. Retention
| Data | Retention period |
|---|---|
| Account, preferences, email address, passenger details, plan and subscription details (clause 3.4), email records and newsletter send records (clause 3.3), and the referral record (clause 3.10) | Until the Account is deleted. The code recorded for a subscription is cleared earlier, when the subscription is replaced. |
| Passenger details entered by a person under 18 | Not stored; the Account is deleted immediately with all data linked to it. The authentication audit log at Supabase and the sending logs at Resend may hold the email address for the period those providers keep such logs. |
| Consent log | While the Account exists and, after its deletion, until 31 December of the sixth year after the year of deletion (Article 118 of the Polish Civil Code). After deletion the records hold no name or email address, only a random identifier and a one-way fingerprint of the address. |
| Telegram chat ID | Until you send /stop, disconnect Telegram or delete the Account |
| Suppression fingerprint: a one-way fingerprint of the address, with the event and its date, kept if you unsubscribed, if your address hard-bounced or if a spam complaint was received, including as a welcome-code requester | Indefinitely, so that the address is not mailed again. An unsubscribe fingerprint is deleted if you confirm the newsletter again in the welcome-code box; a bounce or complaint fingerprint is not. |
| Resend's suppression list | After a hard bounce or spam complaint, Resend keeps the address on its own suppression list, from which deleting the Account does not remove it. |
| Cancellation and withdrawal records (clause 3.8), including a withdrawal made by deleting the Account | Until 31 December of the sixth year after the year of receipt (Article 118 of the Civil Code). A declaration never matched to a Membership: 24 months from receipt. On Account deletion, the link to the Account is removed. |
| Birthday codes | Until 12 months after expiry, or until the Account is deleted if earlier |
| Welcome codes and the fingerprint of the address they were sent to (clause 3.7) | Until 12 months after expiry or use. A code sent to the address of a deleted Account, or used by it, is deleted with the Account. |
| Email address of a welcome-code requester not subscribed to the newsletter through the box | Until 30 days after the code expires or until it is used, whichever is earlier; with a pending newsletter request, at least until the 7-day confirmation period ends; deleted no later than the next day. Deleted immediately when an Account with the same address is deleted. |
| Email address confirmed for the newsletter in the welcome-code box | Until you unsubscribe or a spam complaint is received, then deleted no later than the next day. If you open an Account with that address, the previous row applies. |
| Record of a newsletter consent given in the welcome-code box | Until 31 December of the sixth year after the year of the last event recorded for the address, but never while the subscription or a confirmation is pending. If carried into an Account, for as long as that Account's consent log. |
| Founding number | Indefinitely. The link to the Stripe subscription is removed when the Stripe customer record is deleted, and the link to the Account when the Account is deleted. |
| Request counts (welcome-code box, checkout, cancellation and withdrawal pages) | Two days |
| Invoices and accounting records | Five years from the end of the calendar year in which the tax payment deadline fell (Article 86 of the Tax Ordinance, Article 74 of the Accounting Act) |
| Stripe customer record, if you ever had a Membership | After Account deletion, saved payment methods are removed. The record, including the invoices, is kept until the end of the sixth calendar year after the year of deletion and then deleted. |
| Payment ledger (clause 3.4) | Five years from the end of the tax year of the payment. On Account deletion, the link to the Account is removed. |
| First-payment record (clause 3.10) | While the subscription and any commission rule applying to your payments run. Then, where a Partner counts, five years from the end of the calendar year in which the tax for the last statement including your payments fell due; where no Partner counts, five years from the end of the tax year of your last payment. On Account deletion, the link to the Account is removed and Stripe's customer identifier remains. Until 31 December of the sixth year after the year of deletion we can still link a pseudonym to the closed Account; Partners cannot at any time. |
| Commissions and Partner statements | Five years from the end of the calendar year in which the tax for the statement's tax year fell due (Article 86 of the Tax Ordinance) |
| Fingerprint and note of a personal code (clause 3.9) | Until the code has been used or has ended, or until its holder's Account is deleted, whichever is earlier; an unused code is then deactivated permanently. The note of a partner code is kept with the code. |
| Billing email records (clause 3.4) | Renewal reminders: until 31 December of the sixth year after the year of the renewal concerned. Other billing emails, including the withdrawal notice: 24 months from queuing. On Account deletion, the link to the Account is removed. |
| Log of Stripe notifications | 90 days |
| Correspondence with us | 24 months from the last message in the conversation |
| Server logs | The period set by our hosting providers |
| Page-view statistics (clause 3.5) | As set by Vercel's service terms; we can view them for 12 months |
- Data that cannot be deleted at once, such as data in encrypted backups, is excluded from further use and deleted when the backups rotate.
9. Automated decision-making and profiling
- Deals are selected and published automatically, without processing personal data. Your preferences only filter published Deals. We do not profile you.
- The age check is an automated decision within the meaning of Article 22 of the GDPR: a date of birth showing an age under 18 leads to the refusal and deletion of the Account without human review. It is based only on the date you give and is necessary for entering into the agreement (Article 22(2)(a)). You may contest it and obtain human review at support@aereclub.com.
- We make no other decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.
10. Your rights
- You have the right to access your data and receive a copy, to rectification, to erasure, to restriction of processing and to data portability, and to object, on grounds relating to your particular situation, to processing based on legitimate interests. You may object to direct marketing at any time without giving reasons.
- You may withdraw a consent at any time, without affecting the lawfulness of processing before the withdrawal (marketing email: section 5; Telegram: section 7).
- You can change your first and last name in the Account settings. The date of birth is corrected on request to support@aereclub.com.
- You can delete your Account at any time in the Account settings. The deletion page lists what is deleted and what is kept. After deletion we send a confirmation to the Account's address from mail.aereclub.com; we keep the address only until the confirmation has been sent or sending has been abandoned. Section 10 of the Terms covers a running Membership.
- Send requests to privacy@aereclub.com or support@aereclub.com. We respond within one month; for complex requests this may be extended by up to two further months, of which we inform you within the first month. Requests are free of charge.
- You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work or place of the alleged infringement. The authority competent for us is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych, UODO), ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl.
11. Users in the United States
- We have no company, office or representative in the United States. Users in the United States have the rights set out in section 10.
- We do not sell personal information or share it for cross-context behavioural advertising, do not use it for targeted advertising or for profiling that produces legal or similarly significant effects, and do not collect sensitive personal information. We do not meet the thresholds of the US state consumer privacy laws, such as the California Consumer Privacy Act, which therefore do not currently apply to us.
- The Website does not respond to "Do Not Track" signals, because we do not track users across third-party websites. Apart from Stripe on the checkout page (section 5 of the Cookie Policy), no third party collects personal data about your online activities through the Website.
12. Security
- We apply technical and organisational measures appropriate to the risk, including encrypted connections (HTTPS), password hashing and row-level access control in the database. Card details do not reach us.
- We notify a personal data breach to the supervisory authority and to the persons affected where Articles 33 and 34 of the GDPR require it.
13. External websites
- The booking link of a Deal opens a search on an external flight search website, where that website's privacy policy and cookies apply. The link carries no affiliate or tracking identifier, and we do not see what you do on that website. Other links on the Website lead to websites governed by their operators' policies.
14. Changes to this policy
- We may change this policy. The effective date above identifies the current version. We notify a change that materially affects how we process your personal data by email or by a prominent notice on the Website.
15. Contact
- Data protection questions and requests: privacy@aereclub.com. Formal requests and other matters: support@aereclub.com. General enquiries: info@aereclub.com. All three addresses reach the same monitored mailbox. Our postal address is in section 1.