Privacy Policy

Last updated: August 18, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. We collect, use, and disclose Your information as described in this Privacy Policy and, where required by applicable law, only where We have a valid legal basis to do so, including Your consent (where consent is required).

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access Our Service or parts of Our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Pilot92, the software program provided by the Company.
• Business, for the purposes of the CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information, or on behalf of which such information is collected, and that alone, or jointly with others, determines the purposes and means of the processing of Consumers' personal information, and that does business in the State of California.
• CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to NUMERONAUTICS, 4539 N 22nd St, Ste N, Phoenix, AZ, 85016, Maricopa, United States.
• Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website, among its many uses.
• Country/State refers to: Arizona, United States.
• Device means any device that can access the Service, such as a computer, a cell phone or a digital tablet.
• Do Not Track (DNT) is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You. We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
• Service refers to the Application or the Website or both.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Third-Party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• User means any individual who accesses or uses the Service.
• Website refers to NUMERONAUTICS, accessible from www.numeronautics.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Information

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Bank account information in order to pay for products and/or services within the Service

When You pay for a product and/or a service via bank transfer, We may ask You to provide additional personal information to facilitate this transaction and to verify Your identity and to comply with anti-fraud/legal requirements. Such information may include, without limitation:

• Date of birth
• Passport or National ID card
• Bank card statement
• Other information linking You to an address

Booking and Professional Information

When You request, provide, or participate in coaching, interview-preparation, checkride-preparation, or mentoring services, We may collect booking details, availability, communications, aviation résumés, employment history, certificates, ratings, qualifications, professional experience, and other information You provide in connection with the requested service.

If You apply or register to provide coaching, interview-preparation, checkride-preparation, mentoring, or other professional services through the Service, We may collect information necessary to evaluate Your identity, qualifications, eligibility, and suitability. This information may include Your employment and education history, aviation résumé, professional references, aviation certificates, ratings, licenses, training records, work experience, address history, date of birth, government-issued identification information, and other information You provide during the application or verification process.

With Your authorization and where permitted by applicable law, We may obtain identity-verification, credential-verification, criminal-history, sanctions, public-record, or other background-screening information from third-party screening providers, references, government records, or other lawful sources.

A third-party screening provider may collect sensitive identifiers, such as a Social Security number or government-issued identification number, directly from You. Where practicable, We receive only the verification status, screening results, or other information reasonably necessary to evaluate Your eligibility, qualifications, and suitability to provide services.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-Party Social Media Services:

• Google
• Apple

If You decide to register through or otherwise grant Us access to a Third-Party Social Media Service, We may collect Personal Data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information Collected While Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Pictures and other information from Your Device's camera and photo library

We use this information to provide features of Our Service and to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Tracking Technologies and Cookies

We use tracking technologies (such as cookies) to track the activity and to improve Our Service. The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our Service.
• Web Beacons. Certain sections of Our Service may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
• Email Tracking Technologies. Our emails may contain similar technologies that tell Us whether an email has been opened or a link within it has been clicked. We use this information to measure the performance of Our email communications, to maintain email deliverability, and to understand which content is of interest to You. You can prevent most email tracking by configuring Your email client to block the automatic loading of remote images, and You may opt out of marketing emails entirely by using the unsubscribe link in any marketing email We send.

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

Where required by law, We use non-essential cookies (that is, Cookies other than the Necessary / Essential Cookies described below) only with Your consent. You can withdraw or change Your consent at any time using Our cookie preferences tool (if available) or through Your browser/device settings. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies identify whether users have accepted the use of cookies on the Website and record the consent choices You have made, so that We can honor those choices on future visits.

Functionality Cookies

Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as remembering Your Account login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the Website.

Analytics Cookies

Type: Persistent Cookies
Administered by: Third Parties
Purpose: These Cookies collect information about traffic to the Website and how users use the Website, such as the pages visited, the time spent on those pages, and the source of the visit. Your use to access the Website and may directly or indirectly identify You as an individual visitor. We use this information to understand and improve how the Website performs and to test new pages, features or functionality to see how Our users react to them. The third parties that administer these Cookies may also use the information collected for their own purposes, including to improve their own services.

Use of Your Personal Data

To match students with coaches, interviewers, mentors, or other aviation professionals; arrange and administer bookings; communicate scheduling information; evaluate provider qualifications; and provide the requested preparation or mentoring services.

The Company may use Personal Data for the following purposes:

• To provide and maintain Our Service, including to monitor the usage of Our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that You have already purchased or inquired about. We send such marketing communications only where permitted by applicable law: where prior consent is required (for example, under the laws applicable in the EEA and the UK), We will send them only with Your consent; otherwise, We may send them until You opt out. You may opt out or withdraw Your consent at any time by using the unsubscribe link in any marketing email We send or by contacting Us.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns, and evaluating and improving Our Service, products, services, marketing and Your experience.

Artificial Intelligence Features

Certain features of the Pilot92 Application and Our checkride preparation services use artificial intelligence ("AI") to respond to questions and provide suggestions, feedback, explanations, or other advisory input. When You use these features, We may collect and process the questions, prompts, instructions, responses, feedback, and other content You submit or receive, together with relevant Account and Usage Data necessary to operate the feature.

We use this information to process Your request, generate the requested response, provide and maintain the AI features, monitor safety and security, prevent fraud or abuse, troubleshoot performance, improve Our Service, and comply with legal obligations. We do not use AI features to make decisions about You that produce legal or similarly significant effects.

We may transmit the information You submit through an AI feature to third-party AI technology providers so they can process Your request and generate a response. Where such providers process Personal Data on Our behalf, they act as Service Providers. Before sharing Personal Data with a third-party AI provider, We will provide information about what Personal Data will be shared and how it will be used, and We will obtain Your explicit permission where required by applicable law or platform rules. These providers process information subject to their contractual terms and privacy commitments.

Please do not include sensitive Personal Data, confidential business information, medical information, or Personal Data about another person in an AI request unless it is necessary for the feature and You are authorized to provide it. We retain AI interaction information only for as long as reasonably necessary for the purposes described in this Privacy Policy, subject to the "Retention of Your Personal Data" section below. A third-party AI provider may retain or process information as permitted by Our agreement with that provider and its applicable privacy policy.

AI-generated responses are provided solely as educational and advisory input. They may be inaccurate, incomplete, or outdated and should not be treated as official or authoritative aviation guidance or used as the sole basis for any flight, safety, maintenance, weather, regulatory, or other operational decision.

To verify service providers: To verify the identity, aviation credentials, employment history, education, experience, references, qualifications, eligibility, and suitability of coaches, interviewers, mentors, and other professionals; to conduct or facilitate authorized background screening; to protect Users and the integrity of the Service; to prevent fraud or misrepresentation; and to comply with applicable legal, regulatory, insurance, or contractual requirements.

We may share Your Personal Data in the following situations:

• With Service Providers: We may share Your Personal Data with Service Providers to monitor and analyze the use of Our Service, for payment processing, and to contact You.
• With identity, credential, and background-screening providers: If You apply or register to provide services through the Service, We may disclose information reasonably necessary to verify Your identity, credentials, qualifications, professional history, and background to third-party verification or screening providers. Such disclosures will be made with Your authorization where required and in accordance with applicable law.
• For business transfers: We may share or transfer Your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your Personal Data with Our affiliates, in which case We will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With other users: If Our Service offers public areas, when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside the Service. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent: We may disclose Your Personal Data for any other purpose with Your consent.

With students, coaches, interviewers, and mentors: When You request or accept a booking, We may share information reasonably necessary to arrange and provide the service, such as names, contact information, availability, booking details, aviation résumés, qualifications, and relevant communications. We do not make this information publicly available merely because a User has an Account.

How We Share Your Information

We use the following third-party services to provide app functionality. Each receives only the data necessary to perform its specific function:

• Supabase — our backend database and authentication provider. Stores your account information (email, name), forum posts, logbook entries, and app data. Acts as our data processor for all app data.
• OpenAI — processes your Federal Aviation Regulation (FAR) questions and voice-recorded logbook notes to provide AI-generated answers and transcription. Audio and question text are sent for processing and are not retained by us after the response is returned.
• Google Cloud Vision — processes photos you choose to scan (e.g. pilot certificates, NOTAMs, documents) to extract text. Images are sent for one-time text extraction and are not stored by us afterward; extracted images are not retained on our servers.
• RevenueCat — manages subscription purchases and entitlements. Receives your account identifier and purchase/subscription status. Payment card details are handled entirely by Apple's App Store and are never accessible to us.

Text Messages Privacy Notice

You have the option to receive text (SMS) messages from Us. If You opt in to text messages, We will send You updates, notifications, and other communications as described below. When You opt in, We will collect and store the information You provide in connection with text messaging, such as Your phone number, the date and method of Your consent, and message delivery and read information.

No mobile information will be shared with or sold to third parties or affiliates for marketing or promotional purposes. The phone numbers and consent records We collect for texting are never shared with anyone for any purpose, except the Service Providers that technically have to handle them to deliver the texts.

Consent to receive text messages is not a condition of any purchase or use of Our Service. If You consent to receive SMS from Us, You agree to receive text messages from Us related to:

• Customer care and support
• Account notifications, such as activity, status, or renewal reminders
• Delivery notifications and updates on the status of a delivery
• Authentication messages, such as one-time passwords (OTP) and passcodes
• Security alerts, such as suspicious login attempts or unusual account activity
• Marketing and promotional offers, discounts, and other promotional content

Reply STOP to opt-out. Reply HELP for support. Message & data rates may apply. Messaging frequency may vary. Carriers are not liable for delayed or undelivered messages.

Data We Collect

We collect the following categories of information:

• Account information: email address and name, used to create and manage your account.
• User content: forum posts, chat messages, flight logbook entries, and avatar customization choices you create in the app.
• Photos you choose to submit: for one-time text extraction only (e.g. scanning a pilot certificate or NOTAM). Photos are processed and are not stored on our servers; certificate photos, numbers, and names are saved only on your device.
• Voice recordings: if you use voice-to-text logbook notes, audio is sent for transcription and is not retained after the transcript is returned.
• Subscription and purchase status: to manage your subscription tier. Payment details are handled by Apple, not by us.
• Usage data: limited, non-analytical counters used only to enforce daily usage limits on certain AI-powered features (e.g. FAR AI, NOTAM decoding). Not used for tracking or advertising.

We do not collect your location. We do not use advertising or tracking SDKs, and we do not sell your personal information.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

Account Information

• User Accounts: retained for the duration of Your Account relationship plus up to 30 days after account closure to handle any post-termination issues or resolve disputes.

Customer Support Data

• Support tickets and correspondence: up to 30 days from the date of ticket closure to resolve follow-up inquiries, track service quality, and defend against potential legal claims.
• Chat transcripts: up to 30 days for quality assurance and staff training purposes.

Usage Data

• Website analytics data (cookies, IP addresses, device identifiers): up to 30 days from the date of collection, which allows us to analyze trends while respecting privacy principles.
• Application usage statistics: up to 30 days to understand feature adoption and service improvements.
• Server logs (IP addresses, access times): up to 30 days for security monitoring and troubleshooting purposes.

Marketing Data

• Email Marketing: retained until You unsubscribe or up to 30 days from Your last engagement (last email opened or clicked), whichever comes first.
• Analytics identifiers and profiles: up to 30 days from last interaction or until You opt out, whichever comes first.

Financial and Transaction Data

• Payment information: credit/debit card details are not stored on Our servers; they are processed by Our Payment Service Providers. We retain transaction records (invoice details, purchase history, amounts) for up to 10 years from the date of transaction to comply with tax laws and financial regulations.
• Billing and invoice records: up to 10 years to meet accounting and tax compliance requirements.

Professional and Background Screening Data

Provider applications, professional qualifications, credential-verification records, references, and final screening or eligibility status may be retained for the duration of the application or professional relationship and for up to 24 months after the application is closed or the relationship ends, unless a longer period is required or permitted for legal compliance, dispute resolution, fraud prevention, or the establishment, exercise, or defense of legal claims.

Complete background reports and sensitive supporting documents are retained only for as long as reasonably necessary to complete the evaluation, address any dispute or legally required adverse-action process, and satisfy applicable recordkeeping obligations. They are then securely deleted or destroyed. Where practicable, We retain the final screening status rather than the complete report.

Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.

We may retain Personal Data beyond the periods stated above for different reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us.

When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:

• Deletion: Personal Data is removed from Our systems and no longer actively processed.
• Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with Our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
• Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to - and maintained on - computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and, where relevant, supplementary measures. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

Delete Your Personal Data

You may initiate deletion of Your Account directly within the Pilot92 Application by selecting Profile → Account → Delete Account and following the confirmation instructions. Deleting Your Account will delete or anonymize the Personal Data associated with it, except information We must retain for legal, tax, fraud-prevention, dispute-resolution, or other lawful purposes. You may also contact Us at support@numeronautics.com for assistance.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good-faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Identity, Credential, and Background Screening

We may use third-party Service Providers to verify the identity, aviation credentials, professional licenses, employment history, education, references, and other qualifications of prospective or current coaches, interviewers, mentors, and other professionals. Where appropriate and permitted by law, these providers may also conduct criminal-history, public-record, sanctions, or other background screening.

The screening provider may collect certain information directly from You and process that information under its own privacy notice. Before a screening is initiated, We or the screening provider will identify the applicable provider, explain the screening process, and provide any notices and authorizations required by law.

Checkr — We use Checkr to perform identity, credential, and background-screening services. Its Privacy Policy can be viewed at checkr.com/legal/privacy-policy.

Analytics

We may use third-party Service Providers to monitor and analyze the use of Our Service.

Depending on the provider and how the relevant tool is configured, these analytics providers may also use the information collected on Our Service for their own purposes, including to improve their own services. If You are a California resident, please see the "Sale or Sharing of Personal Information" and "Do Not Sell or Share My Personal Information" sections of this Privacy Policy for more information about these disclosures and Your opt-out choices.

Mixpanel — Mixpanel is provided by Mixpanel Inc. You can prevent Mixpanel from using Your information for analytics purposes by opting out at mixpanel.com/optout. For more information on what type of information Mixpanel collects, please visit Mixpanel's Terms of Use.

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.

Resend — Their Privacy Policy can be viewed at resend.com/legal/privacy-policy.

Payments

We may provide paid products and/or services within the Service. In that case, We may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Apple Store In-App Payments — Their Privacy Policy can be viewed at apple.com/legal/privacy.

RevenueCat — We use RevenueCat to validate purchases, manage subscription entitlements, and process purchase-history information associated with in-app subscriptions. RevenueCat's Privacy Policy is available at revenuecat.com/privacy.

Stripe — Their Privacy Policy can be viewed at stripe.com/us/privacy.

When You pay for a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.

Usage, Performance and Miscellaneous

We may use third-party Service Providers to maintain and improve Our Service.

Invisible reCAPTCHA — We use an invisible CAPTCHA service named reCAPTCHA, operated by Google, to help protect Our Service from spam, fraud, abuse, and automated misuse.

reCAPTCHA may process technical, device, browser, IP address, and interaction data as necessary for security, fraud, and abuse-prevention purposes.

We use reCAPTCHA on the basis of Our legitimate interests in protecting Our Service from fraudulent, abusive, and automated activity.

Google provides the reCAPTCHA service and processes related data on Our behalf only as necessary to provide and maintain reCAPTCHA and to ensure that its security, threat detection, protection, and response capabilities remain effective against evolving threats.

For more information about reCAPTCHA, please see Google's reCAPTCHA FAQ.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which We may collect or may have collected from California residents within the last twelve (12) months.

The categories and examples provided in the list below are those defined in the CCPA/CPRA. Listing a category does not mean that every type of information it describes was in fact collected by Us. It means only that, to the best of Our knowledge, some information within that category may be, or may have been, collected. Certain categories would be collected only if You provided that information to Us directly.

• Category A: Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers. Collected: Yes.
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. Collected: Yes.
• Category C: Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No.
• Category D: Commercial information. Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected: Yes.
• Category E: Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No.
• Category F: Internet or other similar network activity. Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. Collected: Yes.
• Category G: Geolocation data. Examples: Approximate physical location, physical location or movements. Collected: No.
• Category H: Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: Yes. With Your prior permission, We collect pictures and other visual information from Your Device's camera and photo library in order to provide features of Our Application.
• Category I: Professional or employment-related information. Examples: Current or past job history or performance evaluations. Collected: Yes. If You apply or register to provide professional services, We may collect employment history, professional experience, aviation résumés, references, certificates, ratings, licenses, qualifications, credential-verification information, and screening or eligibility status.
• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No.
• Category K: Inferences drawn from other personal information. Examples: A profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No.
• Category L: Sensitive personal information. Examples: Government-issued identifying numbers; a Consumer's account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; genetic data; neural data; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; the contents of mail, email, and text messages (unless the Business is the intended recipient); biometric data; health data; and sexual orientation or sex life. Collected: Yes, in limited circumstances.

We collect this information when reasonably necessary to provide the products, services, or features that You request, authenticate You and secure Your Account (for example, Account log-in credentials in combination with a password), process payments or bank transfers, verify identity, prevent fraud or security incidents, and comply with legal obligations. We collect, use, and disclose sensitive Personal Information only for the purposes permitted by the CCPA/CPRA and its implementing regulations, and We do not collect or use sensitive Personal Information for the purpose of inferring characteristics about You.

Under CCPA/CPRA, Personal Information does not include:

• Publicly available information, meaning: information lawfully made available from federal, state, or local government records; information that the Business has a reasonable basis to believe is lawfully made available to the general public by the Consumer or from widely distributed media; or information made available by a person to whom the Consumer has disclosed it, unless the Consumer restricted the information to a specific audience
• Deidentified or aggregated consumer information
• Information excluded from the CCPA/CPRA's scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on Our Service, from preferences You express or provide through Our Service, or from Your purchases on Our Service.
• From verification and screening sources. For example, from identity-verification providers, credential-verification providers, background-screening providers, professional references, public records, licensing authorities, and other lawful sources.
• Indirectly from You. For example, from observing Your activity on Our Service.
• Automatically from You. For example, through cookies We or Our Service Providers set on Your Device as You navigate through Our Service.
• From Service Providers. For example, third-party vendors to monitor and analyze the use of Our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

Use of Personal Information

We may use or disclose Personal Information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

• To operate Our Service and provide You with Our Service.
• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our Service.
• To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about Our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to You when collecting Your personal information or as otherwise set forth in the CCPA/CPRA.
• For internal administrative and auditing purposes.
• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
• Other purposes consistent with the context in which the information was collected, or as otherwise disclosed to You at the time of collection.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how We use this information, please refer to the "Use of Your Personal Information" section.

If We decide to collect additional categories of Personal Information or use the Personal Information We collected for materially different, unrelated, or incompatible purposes, We will update this Privacy Policy.

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of Personal Information for business or commercial purposes:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity
• Category H: Sensory data
• Category L: Sensitive personal information - Payment processors, financial institutions, identity-verification providers, credential-verification providers, background-screening providers, fraud-prevention providers, professional advisers, and public authorities where required by law.
• Category I: Professional or employment-related information - Identity-verification providers, credential-verification providers, background-screening providers, professional references, licensing authorities, Service Providers, Our professional advisers, and public authorities where required by law.

The categories listed above are those defined in the CCPA/CPRA. Listing a category does not mean that every type of information it describes was in fact disclosed. It means only that, to the best of Our knowledge, some information within that category may be, or may have been, disclosed.

We disclose sensitive Personal Information (Category L) only for business purposes and only to the categories of recipients necessary for those purposes: payment processors and financial institutions to process transactions, identity verification and fraud prevention providers, and Our professional advisors or public authorities where required by law. We do not disclose sensitive Personal Information to advertising or analytics providers, and We do not use it for cross-context behavioral advertising.

When We disclose Personal Information to a Service Provider or contractor for a business purpose, We enter into a contract that describes the purpose, requires the recipient to keep that Personal Information confidential, and prohibits the recipient from using it for any purpose other than the limited and specified purposes stated in the contract, consistent with the CCPA/CPRA.

Categories of Recipients to Whom We Disclose Personal Information

We may disclose, and may have disclosed in the preceding twelve (12) months, the categories of Personal Information identified below to the following categories of recipients for the business purposes described in this Privacy Policy:

• Category A: Identifiers - Service Providers, Our affiliates, analytics and advertising vendors that may use the information for their own purposes (see the "Sale or Sharing of Personal Information" section), and third-party vendors to whom You or Your agents authorize Us to disclose Personal Information in connection with products or services We provide to You.
• Category B: Personal information categories listed in the California Customer Records statute - Service Providers, Our affiliates, and third-party vendors to whom You or Your agents authorize Us to disclose Personal Information in connection with products or services We provide to You.
• Category D: Commercial information - Payment processors, Service Providers, Our affiliates, and third-party vendors to whom You or Your agents authorize Us to disclose Personal Information in connection with products or services We provide to You.
• Category F: Internet or other similar network activity - Service Providers, including analytics providers, Our affiliates, analytics and advertising vendors that may use the information for their own purposes (see the "Sale or Sharing of Personal Information" section), and third-party vendors to whom You or Your agents authorize Us to disclose Personal Information in connection with products or services We provide to You.
• Category H: Sensory data - Service Providers, Our affiliates, and third-party vendors to whom You or Your agents authorize Us to disclose Personal Information in connection with products or services We provide to You.
• Category L: Sensitive personal information - Payment processors, financial institutions, identity-verification and fraud-prevention providers, professional advisers, and public authorities where required by law.

Sale or Sharing of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer's personal information by the Business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

As defined in the CCPA/CPRA, "share" and "sharing" mean disclosing, making available, or otherwise communicating a Consumer's personal information by the Business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

We sell or share Personal Information as those terms are defined in the CCPA/CPRA. We do not sell Personal Information in exchange for money. However, We disclose online identifiers and Internet activity information to third-party vendors in ways that constitute "selling" or "sharing" under the CCPA/CPRA, as described below.

In addition, the analytics providers We use (as described in the "Analytics" section of this Privacy Policy) may use the information collected on Our Service for their own purposes. Because We receive analytics and related services in exchange for making this information available, these disclosures may be deemed a "sale" or "sharing" under the CCPA/CPRA even though no money changes hands.

These vendors place tracking technologies (such as cookies, tags, and pixels) on the Website, and through these technologies, online identifiers and information about Your online activity are disclosed to them.

These disclosures may include disclosures for "cross-context behavioral advertising" as defined in the CCPA/CPRA.

We may disclose or may have disclosed in the last twelve (12) months the following categories in a manner that constitutes a "sale" or "sharing" as defined in CCPA/CPRA:

• Category A: Identifiers
• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Category D: Commercial information
• Category F: Internet or other similar network activity

The categories listed above are those defined in the CCPA/CPRA. Listing a category does not mean that every type of information it describes was in fact sold or shared. It means only that, to the best of Our knowledge, some information within that category may be, or may have been, sold or shared.

Retention of Personal Information

We retain California residents' Personal Information for as long as reasonably necessary to achieve the purposes described in this Privacy Policy (including the purposes disclosed in this CCPA/CPRA notice), taking into account: (i) how long We need the information to provide and maintain the Service and Your Account; (ii) whether You have requested deletion (subject to applicable exceptions); (iii) Our legal, tax, accounting, and regulatory obligations; (iv) security, fraud prevention, and abuse monitoring needs; and (v) the time periods needed to resolve disputes and enforce Our agreements.

Specific retention periods for major data categories are described in the "Retention of Your Personal Information" section of Our Privacy Policy, and We may retain certain information longer where required or permitted by law (for example, to comply with recordkeeping obligations or to establish, exercise, or defend legal claims).

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
• The right to know/access. Under CCPA/CPRA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and sharing of personal information. Once We receive and confirm Your request, We will disclose to You: the categories of personal information We collected about You; the categories of sources for the personal information We collected about You; Our business or commercial purposes for collecting or selling that personal information; the categories of third parties with whom We share that personal information; the specific pieces of personal information We collected about You; and, if We sold or disclosed Your Personal Information for a business purpose, the categories sold and disclosed.
• The right to say no to the sale or sharing of Personal Information (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request, please see the "Do Not Sell or Share My Personal Information" section or contact Us.
• The right to correct Personal Information. You have the right to correct or rectify any inaccurate personal information about You that We collected. Once We receive and confirm Your request, We will use commercially reasonable efforts to correct (and direct Our Service Providers to correct) Your personal information, unless an exception applies.
• The right to limit use and disclosure of sensitive Personal Information. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about You, unless an exception applies. To submit a request, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact Us.
• The right to delete Personal Information. You have the right to request the deletion of Your Personal Information under certain circumstances, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your Personal Information from Our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to: complete the transaction, provide a requested good or service, or perform a contract with You; detect security incidents or protect against fraud; debug products; exercise free speech rights; comply with the California Electronic Communications Privacy Act; engage in public-interest research with prior consent; enable internal uses reasonably aligned with Your expectations; comply with a legal obligation; or make other internal, lawful uses compatible with the context in which You provided the information.
• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer rights, including by denying goods or services to You, charging different prices or rates, providing a different level or quality of goods or services, or suggesting You will receive a different price, rate, level, or quality of goods or services.

Exercising Your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell or Share My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of Your rights under the CCPA/CPRA, and if You are a California resident, You can contact Us by email: info@numeronautics.com.

We may verify Your identity before responding to requests to know, delete, or correct Personal Information, as permitted or required by applicable law. We will not require You to submit a verifiable consumer request to opt out of the sale or sharing of Personal Information or to limit the use or disclosure of Sensitive Personal Information. For those requests, We may ask only for information reasonably necessary to identify the Personal Information to which the request applies and process the request.

Only You or an authorized agent acting on Your behalf may make a verifiable request relating to Your Personal Information.

Your request to Us must provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Information or an authorized representative, and describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with the required information if We cannot verify Your identity or authority to make the request, and confirm that the personal information relates to You.

No later than 10 business days after receiving a request to know, delete, or correct, We will confirm receipt and provide general information about how We will process and verify the request and when You should expect a response, unless We have already granted or denied the request. We will respond no later than 45 calendar days after receipt. If reasonably necessary, We may extend the response period once by an additional 45 calendar days. If We do, We will notify You during the initial 45-day period and explain the reason for the extension.

Unless You request a longer period, Our response to a request to know will cover the preceding 12 months. You may request information collected on or after January 1, 2022, for a longer period, unless providing it is impossible or requires disproportionate effort. We are not required to retain Personal Information for any specific period.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell or Share My Personal Information

You have the right to opt out of the sale and sharing of Your Personal Information. To exercise this right, contact Us using the methods listed in the "Contact Us" section, or follow the instructions below. We will not require You to create an account or verify Your identity in order to opt out, although We may ask for information reasonably necessary to identify the Personal Information to which Your request applies and to process the request.

Opt-Out Preference Signals (Global Privacy Control)

Our Service recognizes and honors opt-out preference signals, such as the Global Privacy Control (GPC), as required by the CCPA/CPRA. If Your browser or browser extension transmits a legally recognized opt-out preference signal, We will treat it as a valid request to opt out of the sale and sharing of Personal Information linked to that browser or device and, where We can reasonably associate the signal with You, to Your Account. You may need to enable the signal separately on each browser and device that You use.

Please note that the other opt-out methods described below are specific to the browser You use. You may need to opt out on every browser that You use.

Website

Use the "Privacy Preferences" / "Update Privacy Preferences" control on the Service, to review Your privacy preferences and opt out of cookies and other technologies that We may use.

Additionally, You can opt out of receiving ads that are personalized as served by Our Service Providers by following Our instructions presented on the Service:

• The NAI's opt-out platform: networkadvertising.org/choices
• The EDAA's opt-out platform: youronlinechoices.com
• The DAA's opt-out platform: optout.aboutads.info

The opt-out will place a cookie on Your computer that is unique to the browser You use to opt out. If You change browsers or delete the cookies saved by Your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Limit the Use or Disclosure of My Sensitive Personal Information

If You are a California resident, You have the right to limit the use and disclosure of Your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods.

We collect, use and disclose sensitive personal information only in ways that are necessary to provide the Service. For more information on how We use Your personal information, please see the "Use of Your Personal Information" section or contact Us.

To submit a request to limit the use or disclosure of sensitive personal information, please contact Us using the methods listed in the "Contact Us" section of Our Privacy Policy. We will not require You to verify Your identity in order to submit a request to limit, although We may ask for information reasonably necessary to process the request.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third-party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code § 1798.83 (California's Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If You would like to make such a request, or to ask that We not disclose Your Personal Information to third parties for their direct marketing purposes, please submit Your request in writing using the contact information provided in the "Contact Us" section of this Privacy Policy.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your Account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Personal Information of Minors Under 16 Years of Age

The Service is not directed to, and We do not knowingly collect Personal Information from, anyone under the age of 16 through Our Service, although certain third-party websites that We link to may do so. These third-party websites have their own terms of use and privacy policies and We encourage parents and legal guardians to monitor their children's Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the Personal Information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the "right to opt-in") from the parent or guardian of a Consumer less than 16 years of age. Consumers who opt-in to the sale of Personal Information may opt out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 16 has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

If You are a parent or guardian and You believe Your child has provided Us with Personal Information, please contact Us. If We become aware that We have collected Personal Information from anyone under the age of 16, We will take steps to remove that information from Our servers as soon as reasonably possible.

Some countries and states set a higher age at which an individual can consent to the processing of their own Personal Information. Where We rely on consent as a legal basis and the law applicable to a User sets an age higher than 16, We may require the consent of that User's parent or guardian before We collect and use their Personal Information.

Links, Changes, and Contact

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If You have any questions about this Privacy Policy, You can contact Us by email: info@numeronautics.com