Privacy Policy

DaVinci Aero Systems Management Ltd ("DVAS", "we", "us", or "our") is committed to protecting personal information processed through the DaVinci Platform and related services (the "Platform").

This Privacy Policy explains how we collect, use, disclose, store, and protect information in connection with the Platform.

1. Who We Are

DaVinci Aero Systems Management Ltd is a company incorporated in the Dubai International Financial Centre (DIFC), United Arab Emirates, and is subject to the DIFC Data Protection Law (DIFC Law No. 5 of 2020, as amended).

For most Platform activities, DVAS acts as the controller of personal information processed through the Platform.

In sovereign, government-hosted, or authority-operated deployments, the relevant Civil Aviation Authority or governmental entity may act as the controller of certain information, with DVAS acting as a processor.

For privacy-related inquiries, contact: info@dvas.aero

2. Information We Collect

Account Information

We collect information relating to Platform users, including:

• Name
• Business email address
• Telephone number
• Job title
• Organisation and department
• User role and permissions
• Authentication and login records

Identity and Compliance Information

Users may provide documentation for identity verification, KYC, onboarding, or regulatory compliance purposes, including:

• Passports, national identity cards, Emirates IDs, and driver's licences
• Corporate registration documents and beneficial ownership information
• Powers of attorney
• Aircraft certificates and aviation permits
• Passenger tickets and travel documents
• Remittance records and supporting documentation

Payment Information

When payments are made through the Platform, we collect:

• Billing information
• Payment confirmations and transaction identifiers
• Payment status records and remittance documentation

Payment card information is processed by authorised third-party payment providers and is not stored by DVAS except where required for reconciliation, compliance, or legal purposes.

Technical Information

We automatically collect:

• IP addresses and device information
• Browser and session information
• Authentication and access logs
• Security event records

Aviation and Operational Information

The Platform processes aviation-related operational information, including:

• Aircraft registrations and identifiers
• Flight plans and routing information
• Airspace activity and flight tracking records
• Air navigation fee records and permit information
• Operational analytics

This information is operational aviation data and is not collected for the purpose of identifying individuals.

3. How We Use Information

We use information to:

• Operate the Platform and manage user accounts;
• Authenticate users and provide support;
• Verify identity and conduct KYC checks;
• Process payments and administer Air Navigation Fees;
• Generate invoices and payment records;
• Monitor Platform security and detect fraud or unauthorised activity;
• Comply with legal and regulatory obligations;
• Respond to governmental or regulatory requests; and
• Enforce our contractual rights and Terms of Use.

4. Sharing of Information

Civil Aviation Authorities and Governmental Entities

We may disclose information to civil aviation authorities and governmental entities where necessary to provide services, process payments, administer Air Navigation Fees, or comply with legal obligations.

Data provided by or belonging to a civil aviation authority or governmental entity is treated as confidential. DVAS does not sell, license, or otherwise transfer such data to any third party.

Aviation Data

Aircraft registrations, flight paths, flight history, airspace activity records, and other publicly observable aviation data may be shared with or sold to third parties for commercial, analytical, or operational purposes. This category does not include any data provided by or attributable to a specific governmental authority.

Service Providers

We engage service providers for cloud hosting, data storage, infrastructure management, payment processing, security monitoring, and compliance activities. These providers access information only as necessary to perform services on our behalf and are bound by confidentiality obligations.

Legal and Regulatory Authorities

We disclose information where required by law, court order, governmental request, or regulatory obligation.

5. International Transfers

DVAS operates internationally. Information may be stored, processed, or accessed across multiple jurisdictions. Where information is transferred outside the DIFC, DVAS takes steps to ensure such transfers comply with the DIFC Data Protection Law, including through appropriate contractual safeguards where required.

By using the Platform, users acknowledge that information may be transferred across international borders as necessary to provide services.

6. Data Retention

DVAS retains information for as long as necessary to provide services, meet legal and regulatory obligations, resolve disputes, conduct audits, and maintain operational and historical records. Information may remain in backups, archives, or disaster recovery systems for additional periods.

Account closure does not require immediate deletion of associated records.

7. Cookies and Similar Technologies

The Platform uses cookies and similar technologies to authenticate users, maintain secure sessions, support Platform functionality, and improve security. Additional technologies may be introduced as the Platform evolves.

8. Security

DVAS implements administrative, technical, and organisational measures to protect information against unauthorised access, disclosure, alteration, or destruction. No system guarantees absolute security, and users acknowledge that transmission and storage of information carry inherent risks.

9. User Rights

Under the DIFC Data Protection Law, users may have the right to:

• Access their personal information;
• Correct inaccurate information;
• Request deletion of information;
• Request restriction of processing;
• Object to certain processing activities; and
• Withdraw consent where consent is the basis for processing.

These rights may be limited where information must be retained for legal, regulatory, contractual, aviation, payment, compliance, or audit purposes.

Requests may be submitted to info@dvas.aero.

10. Third-Party Services

The Platform may integrate with third-party payment providers, banking systems, aviation systems, and regulatory platforms. DVAS is not responsible for the privacy practices of third-party services that operate independently from the Platform.

11. Changes to This Privacy Policy

DVAS may update this Privacy Policy from time to time. Updated versions will be published through the Platform or associated websites and will take effect upon publication unless otherwise stated.

12. Contact

DaVinci Aero Systems Management Ltd
Dubai International Financial Centre, United Arab Emirates
Email: info@dvas.aero