SW Virtual GDPR Privacy Policy

Last Updated: July 3, 2025

This privacy policy explains how the SW Virtual („we“, „our“, or „us“) processes personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR) and Act No. 110/2019 Coll., on the Processing of Personal Data (Czech law)

1. Data Controller & Contact

Controller: SW Virtual
Support & Privacy Email: support@sw-virtual.eu

2. Personal Data We Collect

All personal data processed by SW Virtual comes exclusively via our support email, and includes:

  • First Name
  • Last Name
  • Email Address
  • Pilot ID (a unique user system identifier used for the Flight Map – visible publicly)

We do not collect any other personal data (e.g., phone numbers, addresses, IPs).

3. Purposes & Lawful Basis

We process your data exclusively to:

  1. Respond to your support or service-related inquiries
  2. Provide helpdesk support
  3. Improve the quality of our services
  4. Display currently flying users for our airline in the flight simulator

Our lawful basis under GDPR is legitimate interests—processing is necessary for providing the support you reasonably expect, has minimal privacy impact, and aligns with SW Virtual’s operational needs.

We do not use your personal data for marketing purposes without your consent.

4. Flight Map Data

The Pilot ID is a unique identifier assigned to a specific user. While it does not publicly disclose a name or contact details, it may still qualify as personal data under GDPR, as it can relate to an identifiable individual.

The System ID is displayed only during an active flight session on the public flight map.

No additional personal data is displayed on the map.

All map data, including the System ID, is automatically deleted immediately after the flight ends. No history is retained.

Processing is based on our legitimate interest to provide a live visualization feature for community members and the public.

5. Data Minimization & Storage Limitation

  • We collect only the necessary information (name and email).
  • Data is stored only as long as needed for support purposes, i.e., until you request deletion .
  • Although our retention is indefinite by default, data will be erased promptly upon your request.

6. Accuracy & Data Integrity

We take reasonable steps to ensure your information remains accurate. If we’re made aware of errors, we promptly correct or erase the data.

7. Security Measures

We implement appropriate security measures to protect your information, including encryption, access controls, and secure data storage.

8. No Third‑Party Sharing

Your PII is not shared with third parties, except when legally required (e.g., in response to lawful requests by authorities).

9. Your GDPR Rights

Under GDPR, you have the following rights regarding your data:

  • Access – request copies of any personal data we hold
  • Rectification – correct inaccuracies
  • Erasure – request deletion (“right to be forgotten”)
  • Restriction – limit processing
  • Portability – receive your data in a structured format
  • Objection – contest processing based on legitimate interests

To exercise any of these rights, email us at support@sw-virtual.eu. You also have the right to lodge a complaint with your relevant EU Supervisory Authority.

10. Accountability & Documentation

In compliance with GDPR’s accountability principle, SW Virtual:

  • Maintains internal records of processing activities
  • Periodically reviews retention policies to ensure we aren’t holding unnecessary personal data.

11. Updates to This Policy

We may update this policy due to legal or operational changes. The “Last Updated” date will be revised accordingly, and material updates will be communicated publicly.