HERO Aviation Privacy Policy
HERO Aviation, LLC, a Texas limited liability company (“HERO,” “we,” or “us”), provides a safety management platform with duty- and schedule-based fatigue awareness (the “Platform”). This Privacy Policy describes how we collect, use, disclose, and protect personal information. It is written to be compatible with the California Consumer Privacy Act as amended by the CPRA, and it applies to Platform users, operator personnel, and visitors to our websites.
HERO’s role. For the duty and schedule records your operator supplies and the fatigue-exposure indicators computed from them, HERO acts as a service provider and processor on your operator’s behalf; your operator is the controller and business for that information. For our websites, account records, and inquiries submitted to us, HERO acts on its own behalf. HERO computes fatigue-exposure indicators; your operator reviews them and makes any fitness-for-duty determination. An indicator is one input to your operator’s decision and is not itself a determination that any individual is fit or unfit for duty.
1. Information We Collect
Account information: name, work email, employer/operator, role, credentials.
Derived fatigue-exposure data: indicators our Platform computes from duty and schedule records.
In this Policy, a “fatigue-exposure indicator” means a value the Platform calculates from duty and schedule records to show the degree to which a crew member’s recent duty pattern is associated with fatigue risk. A “FRAT” means a flight risk assessment tool, a structured checklist your operator uses to score the risk of a planned flight, and “FRAT inputs” means the answers entered into it.
Operational data: duty and schedule records (duty on and off times, consecutive duty days, planned and actual flight time, and rest periods), FRAT inputs, and related information supplied by you or your operator, including operational identifiers and counts that legitimately appear in flight and dispatch records — dispatch or CAD numbers, incident numbers, aircraft and crew identifiers, and passenger counts.
Device and usage data: log data, device identifiers, app interactions.
What we do not collect: face scans, fingerprints, voiceprints, or other biometric identifiers. We do not collect genetic information or family medical history. We do not collect wearable, device, biometric, or health-sensor data. The Platform is also not configured to receive, and you and your operator must not enter in free-text fields, patient names or medical detail, protected health information, criminal-justice or law-enforcement case content, export-controlled data, or payment card data, unless HERO has executed a written addendum covering that category and confirmed in writing that the required security and compliance capabilities are in place.
2. How We Use Information
We use personal information to: provide and support the Platform; compute fatigue-exposure indicators; display information to you and to your operator; secure the Platform; comply with law; and — only in de-identified, aggregated form — improve and validate the Platform. We do not sell personal information, and we do not share it for cross-context behavioral advertising. We do not use your information for marketing.
3. How We Disclose Information
We disclose personal information only: (a) to your operator; (b) to service providers (hosting, source code, and email relay) bound by contracts limiting their use to our instructions; (c) to comply with law or legal process; (d) in a merger, acquisition, or asset sale, subject to this Policy; and (e) with your direction or consent. Our service providers fall into these categories: cloud hosting, compute and database services; source-code hosting; website hosting; contact-form email relay; and business email. We provide the current list on request and give operators advance notice before adding or replacing a subprocessor as described in the Data Processing Addendum. Providers we may add later (for example messaging, payment, accounting or transactional-email services) are not in use today and would be added only through that notice mechanism.
4. Where Information Is Processed
Data that HERO controls is stored in United States regions with our cloud hosting provider. Source code is held with a source-code hosting provider under multi-factor authentication, and our marketing website is hosted separately.
We cannot represent that all processing occurs solely in the United States, and we do not. Our hosting provider operates a global network, and traffic may transit non-United States points of presence even where stored data is region-pinned to the United States.
5. Sensitive Information
We do not collect wearable, device, biometric, or health-sensor data. Duty and schedule records are your operator’s personnel records and are treated as your operator’s confidential information.
6. Retention and Deletion
We retain personal information only as long as needed for the purposes above: active-account data for the subscription term; fatigue-exposure indicators and operational records for the periods set out in the schedule below; and backup copies for the backup cycle stated in that schedule. When your operator’s agreement ends, we return or delete operator data per that agreement and the Data Processing Addendum. We review this schedule periodically and post any change here.
The following retention periods apply:
| Data category | Retention period |
|---|---|
| Operational records (hazard reports, flight logs, certifications, duty and schedule records, and fatigue-exposure indicators) | 5 years, or until deleted at the end of your operator’s subscription under its agreement with HERO, whichever is earlier; your operator, not HERO, is the official record holder |
| Backups | 35 days, then overwritten; a deletion is honored in live systems within thirty (30) days and flows through backups within the backup cycle |
| De-identified and aggregated data | Retained indefinitely; no re-identification |
Deletion triggers. When your operator removes a crew member as a user or notifies us of a separation, we delete that member’s personal information within thirty (30) days. When your operator’s subscription terminates or expires, your operator has sixty (60) days to export its data or to request deletion, as described in the Data Processing Addendum.
De-identified and aggregated data. We create and retain de-identified, aggregated data indefinitely for platform improvement, validation, and benchmarking. We maintain that data in de-identified form, do not attempt to re-identify it, and contractually prohibit recipients from re-identifying it.
7. Your Rights and Choices
Depending on your state of residence, you may have rights to know, access, correct, delete, or port personal information, and to limit use of sensitive personal information, without discrimination for exercising them. To exercise rights, contact us at the address below; we will verify your request and respond within the time required by applicable law. Where your data is processed on behalf of your operator, we will promptly forward your request to your operator, which is responsible for responding to it, and we will assist your operator as required by law. We do not retaliate, and your employment rights are matters between you and your employer.
8. Security
We maintain reasonable and appropriate administrative, technical, and physical safeguards appropriate to the sensitivity of the data. A description of our current measures is available to your operator on request. HERO’s personnel, which may include its manager and any contractors HERO engages, are bound by written confidentiality obligations. No system is perfectly secure; we will notify affected operators and individuals of security incidents as required by law and by contract.
9. Website Visitors and Contact Form
Our marketing website is hosted by a third-party website host and uses that host’s built-in visitor analytics only. We do not add third-party analytics, advertising pixels, or third-party cookies, and we do not send SMS messages.
Cookies. The Platform and our website use first-party cookies and similar session storage that are necessary to sign you in, keep you signed in during a session, remember your display preferences, and protect against fraud and abuse. Our website host’s built-in analytics set first-party cookies that count visits and page views. You can block or delete cookies through your browser settings; if you block the cookies necessary for sign-in, the Platform will not function.
Do Not Track and opt-out preference signals. We do not collect information about your online activities over time and across third-party websites or online services, and we do not permit third parties to do so through our website or the Platform. Because we do not engage in that collection, a browser “Do Not Track” signal or a global opt-out preference signal has no effect on what we collect, and we do not respond to those signals other than as described in this Policy. If this changes, we will update this Policy before the change takes effect.
If you submit our contact form, the submission is handled two ways: a contact-form handler stores the inquiry (name, organization, contact information, message, and status) in our U.S.-region database, retained for twenty-four (24) months from our last contact; and an email-relay service forwards the same message to our business mailbox. We use inquiry information only to respond to the inquiry — we do not build marketing lists from it and we do not sell it. An archived spreadsheet of early inquiries is frozen.
We do not currently offer online payment, a storefront, cart, checkout, scheduling, or booking function on our website, and we have never taken an online payment. If we add any such function, we will update this Policy to describe the information it collects before that function becomes available.
10. Children
The Platform is a workforce tool and is not directed to anyone under 18. We do not knowingly collect information from minors.
11. Changes; Contact
We will post updates to this Policy with a new effective date and give notice of material changes through the Platform or your operator. Questions or requests: HERO Aviation, LLC, 126 Bess Street, Boerne, TX 78006 — privacy@heroaviationusa.com.
Complaints and requests. To ask a question, make a privacy request, or raise a complaint about how we handle personal information, write to us at the postal address or email address above. We acknowledge requests within ten (10) business days and respond within forty-five (45) days, and we will tell you if we need additional time. That email address is also our designated request address for a verified request not to sell covered information; we do not sell personal information.
Where this Policy is posted. This Policy is available through a link marked “Privacy” on the home page of our website and within the Platform.