Effective Date: August 21, 2026
Entity: AeroDev (Pty) Ltd trading as TimeWellSpent / TWS
Portfolio Scope: TWS Log, TWS Cabin, TWS Drone, TWS Nav, and all future TWS products
Contact Email: support@tws.software

AeroDev (Pty) Ltd ("Company", "we", "us", or "our") respects your privacy and is committed to protecting the personal data of users ("User", "you", or "your") across our software suite. This Privacy Policy applies to all applications, mobile apps, websites, and services offered under the TimeWellSpent / TWS portfolio, including TWS Log, TWS Cabin, TWS Drone, TWS Nav, and any future products developed by AeroDev (Pty) Ltd (collectively, the "TWS Products").

This Policy explains how we collect, use, store, and safeguard your information in accordance with the Protection of Personal Information Act (POPIA) of South Africa, the General Data Protection Regulation (GDPR), and applicable global data privacy laws.

1. Information We Collect Across the TWS Product Suite

We collect personal and operational data necessary to deliver digital aviation, cabin crew, drone, and navigation record-keeping and planning tools.

A. Personal & Account Information (All Products)

Full name, contact email address, phone number, and physical/billing address details. Account credentials and subscription transaction histories (payment processing details are handled securely via PCI-DSS compliant third-party gateways and are never stored directly on our servers).

B. Product-Specific Operational & Regulatory Data

Depending on which TWS Products you utilize, we process:

TWS Log: Flight log entries (aircraft registration, flight hours, aerodromes, crew roles, approaches), pilot licence details, ratings, and medical certificate expiry dates.
TWS Cabin: Flight duty hours, cabin crew line check evaluations, performance summaries, training records, and qualification expiry dates.
TWS Drone: Remote Pilot Licence (RPL) details, Remote Operator Certificate (ROC) details, RPAS/drone hardware serial numbers, flight logs, payload data, and operational location logs.
TWS Nav: Flight planning routes, waypoints, aircraft performance profiles, altitude metrics, and device location/GPS data during active navigation sessions.
Document Uploads (All Products): Any PDF, image, or digital document uploaded to our platforms (e.g., test sheets, flight plans, licences, airworthiness certificates, or line check forms).

C. Technical & Usage Data

IP address, hardware model, operating system, application version, error/crash logs, and session tokens essential for offline data synchronization and multi-device access.

2. How We Use Your Data (Our "Zero-Sale" Promise)

Our Portfolio Commitment: We use your data exclusively to provide, operate, maintain, and enhance the TWS Product family. We do not sell, rent, lease, trade, or monetize your personal information, operational logs, flight plans, or uploaded documents to any third parties for advertising or commercial purposes.

We use your data strictly to:

• Deliver core functionality across TWS Log, TWS Cabin, TWS Drone, TWS Nav, and future TWS Products.
• Synchronize data seamlessly between mobile devices and web platforms (including offline-first capabilities).
• Generate official regulatory summaries (such as SACAA-compliant career reports).
• Process subscription transactions and manage your user account.
• Provide technical support, security patches, and critical operational updates.
• Protect platform security, prevent unauthorized access, and enforce our Terms of Service.

3. Data Storage & Security Safeguards

We maintain administrative, physical, and technical safeguards designed to protect your information across all TWS Products:

Encryption in Transit: All data transmitted between your web browser or mobile app and our servers is encrypted using industry-standard TLS/SSL (HTTPS) protocols.
Network Isolation & Access Control: Production environments and database servers are protected by firewall policies, restricted private network configurations, and administrative access controls limited strictly to authorized personnel.
Operational Monitoring: We monitor our infrastructure for operational integrity and performance to protect against unauthorized access or system disruptions.

4. Subprocessors & Data Sharing

We only share information with vetted third-party service providers (Subprocessors) necessary for operating the TWS Product ecosystem:

Cloud Infrastructure Providers: Secure cloud hosters and data center facilities hosting our web applications, database infrastructure, and document repositories.
Billing Processors: Certified payment gateways handling subscription billing.

All Subprocessors are bound by strict data processing agreements enforcing confidentiality and data protection standards consistent with POPIA and GDPR.

5. Security Disclaimer & Breach Notification

Despite our security measures, no online storage system or internet transmission can be guaranteed 100% immune to all technical failures, unauthorized access, or cyber threats.

If a security breach or unauthorized access occurs that impacts your personal data, AeroDev (Pty) Ltd will:

• Notify affected users via email without undue delay.
• Notify the South African Information Regulator and relevant data protection authorities as mandated by POPIA Section 22.
• Implement immediate containment, remediation, and system hardening measures.

6. Data Retention & Your Rights

A. Data Retention

We retain your logs, documents, and account data for as long as your TWS subscription account remains active, or as required to comply with statutory legal, aviation regulatory, and financial reporting obligations.

All your user data may be deleted 24 months after your subscription expiry date.

B. Your Privacy Rights

Under POPIA and applicable global privacy legislation, you have the right to:

• Access: Request a report of the personal data we hold across the TWS product line.
• Correction: Request corrections to inaccurate personal details.
• Deletion: Request account closure and data deletion (subject to legal retention requirements).
• Data Portability: Export your logbook, line check, drone, and navigation data via in-app export tools at any time.

To exercise these rights, submit a request to our Information Officer at support@tws.software.

Please also see our Terms of Service.

Version v1, published 2026-09-28