1. Introduction
This Privacy Policy sets out how Aerosim (HK) Ltd and its research division Aerotyrnd (“we”, “us”, “our”) handle personal information in connection with the Universal Aviation Aptitude Test (“UAAT”) platform. We are committed to complying with applicable privacy and data protection laws in the jurisdictions in which we operate, including Hong Kong and Australia.
By accessing or using the UAAT platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the platform.
2. Personal Information We Collect
We only collect personal information that is reasonably necessary for the operation of the UAAT platform. The kinds of personal information we may collect include:
| Category | Examples |
|---|---|
| Identity information | Full name, email address, username, profile photograph |
| Account credentials | Hashed password, OAuth tokens (via authentication provider) |
| Assessment data | Module scores, test responses, session recordings, radio communication transcripts, performance analytics |
| Organisation data | Flight school, university, or airline affiliation; instructor assignments; role within organisation |
| Transaction data | Token purchase history, credit balances, payment references |
| Technical data | IP address, browser type, device information, session cookies, usage logs |
We do not intentionally collect sensitive information unless it is reasonably necessary and you have consented. Aviation medical information is not collected through this platform.
3. How We Collect Personal Information
We collect personal information directly from you when you register an account, complete assessments, interact with the platform, or communicate with us. In some cases, we may receive personal information from third parties, including:
- Your organisation (flight school, university, or airline) when they register you as a candidate or student
- Authentication providers when you sign in via third-party login
- Analytics services that provide aggregated usage data
Where practicable, we will collect personal information directly from you. If we receive unsolicited personal information that we could not have lawfully collected, we will destroy or de-identify it as soon as practicable.
4. How We Use Your Personal Information
We collect, hold, use, and disclose personal information for the following purposes:
- To provide, administer, and improve the UAAT assessment platform
- To authenticate your identity and manage your account
- To deliver assessment modules, generate scores, and produce performance reports
- To process AI-powered analysis of your assessment responses (including communication exercises analysed by large language models)
- To enable your organisation (if applicable) to view your assessment results and training progress
- To process token purchases and manage credit balances
- To communicate with you about your account, assessments, or platform updates
- To comply with applicable laws, regulations, and aviation authority requirements
- To conduct research and development to improve assessment methodologies (using de-identified data where possible)
We will not use or disclose personal information for a purpose other than the primary purpose of collection, unless permitted by applicable law (for example, where you have consented, or the secondary purpose is directly related and reasonably expected).
5. AI and Automated Processing
The UAAT platform uses artificial intelligence, including large language models (LLMs), to:
- Simulate air traffic control communications during the Communication module
- Evaluate and score your radio phraseology, readback accuracy, and situational awareness
- Generate personalised feedback on assessment performance
- Produce scenario-specific content (ATIS broadcasts, ATC instructions)
Your assessment responses are processed by AI systems hosted on secure cloud infrastructure. We do not use your personal assessment data to train AI models. AI-generated scores and feedback are supplementary to the standardised assessment framework and are subject to quality assurance review.
6. Cross-Border Data Disclosure
As an international platform, personal information may be transferred to or processed in jurisdictions outside your country of residence. This may include:
- Cloud infrastructure: Our platform is hosted on cloud services with data centres in multiple jurisdictions, including the United States, Singapore, and the Asia-Pacific region
- AI processing: Assessment data may be processed by AI services located in the United States
- Corporate group: Aerosim (HK) Ltd is incorporated in Hong Kong SAR, and data may be shared within our corporate group for operational purposes
Before transferring personal information across borders, we take reasonable steps to ensure that the recipient provides a comparable level of data protection and that appropriate safeguards are in place.
7. Data Security
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. Our security measures include:
- Encryption of data in transit (TLS/SSL) and at rest
- Secure authentication via OAuth 2.0 with session-based access control
- Role-based access controls limiting data visibility to authorised personnel
- Regular security reviews and monitoring of platform infrastructure
- Secure cloud storage with access logging
We will take reasonable steps to destroy or de-identify personal information once it is no longer needed for any purpose for which it may be used or disclosed, unless we are required by law to retain it.
8. Access to and Correction of Personal Information
You have the right to request access to the personal information we hold about you and to request correction of any information that is inaccurate, out-of-date, incomplete, irrelevant, or misleading.
You can access and update much of your personal information directly through your UAAT account settings. For requests that cannot be handled through the platform, or to request a copy of all personal information we hold about you, please contact us using the details in Section 10 below.
We will respond to access and correction requests within 30 days. If we refuse a request, we will provide written reasons and information about how you may seek further recourse.
9. Data Retention
Assessment records, including scores and performance data, are retained for the duration of your account and for a reasonable period thereafter to support verification requests from aviation authorities, flight schools, and airlines. This retention period reflects the operational requirements of the aviation training industry, where historical assessment data may be relevant to ongoing licensing and employment processes.
You may request deletion of your account and associated data by contacting us. We will action such requests within 30 days, subject to any legal obligations requiring us to retain certain records.
10. Complaints and Contact
If you have any concerns about how we handle your personal information, or wish to make a complaint, please contact us at:
We will acknowledge your complaint within 7 days and endeavour to resolve it within 30 days. If you are not satisfied with our response, you may be entitled to lodge a complaint with the relevant privacy or data protection authority in your jurisdiction.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on the platform with a revised “Last updated” date. We encourage you to review this policy periodically.