TK Virtual respects the privacy of its pilots, staff, applicants and website visitors. We process only data that is required for the operation, administration, security and development of the Virtual Airline and its related services.
1. Data Controller
For personal data processed directly by TK Virtual, TK Virtual management is responsible for determining the purposes and means of processing.
Privacy questions and requests concerning personal data can be submitted using the email address above.
2. Personal Data We Process
The exact information processed depends on how a person interacts with TK Virtual.
Membership and account information
- Name or display name
- Email address
- TK Virtual pilot identifier
- VATSIM CID where provided or required
- Membership status
- Pilot rank
- Registration and membership information
- Account preferences and profile information
Flight and operational information
- Date of flight
- Flight number and callsign
- Departure airport
- Arrival airport
- Flight route
- Aircraft type
- Flight duration
- Network used for the flight
- Flight status
- PIREPs and operational records
- Other information necessary to verify a submitted flight
Discord and community information
- Discord username
- Discord user identifier
- Server roles
- Verification and membership association information
Technical information
- IP address
- Browser and device information
- Date and time of access
- Requested pages and resources
- Server and security logs
- Information required for authentication and session security
3. Sources of Personal Data
Personal data may be obtained directly from the user, generated through the use of TK Virtual services, or obtained from services used for Virtual Airline operations.
This may include information provided by VATSIM, vAMSYS, Discord or other services used by TK Virtual, where such information is available to TK Virtual and its use is permitted.
Publicly available flight information may also be used to verify activity and maintain operational records.
4. Purposes of Processing
TK Virtual may process personal data for the following purposes:
- Creating and administering memberships
- Authenticating users
- Managing pilot profiles, ranks and activity
- Recording, reviewing and verifying flights
- Maintaining pilot and flight statistics
- Operating leaderboards and activity systems
- Managing Discord verification and community access
- Responding to support and privacy requests
- Preventing abuse, manipulation and fraudulent submissions
- Maintaining website and system security
- Troubleshooting technical problems
- Communicating operational or membership information
- Maintaining historical Virtual Airline records
- Demonstrating Virtual Airline activity where verification is required
5. Legal Basis for Processing
Where the General Data Protection Regulation applies, TK Virtual processes personal data only where an appropriate legal basis exists.
Article 6(1)(a) GDPR: Consent
Where processing is based on consent, the user may withdraw that consent at any time for future processing. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.
Article 6(1)(b) GDPR: Requested services
Processing may be necessary to provide membership, account or Virtual Airline services requested by a user.
Article 6(1)(c) GDPR: Legal obligations
Personal data may be processed where TK Virtual is required to comply with an applicable legal obligation.
Article 6(1)(f) GDPR: Legitimate interests
TK Virtual may process information where this is necessary for legitimate interests such as system security, fraud prevention, administration, flight verification, maintaining operational records and protecting TK Virtual services, provided those interests are not overridden by the rights and freedoms of the individual.
6. Flight Data and VATSIM
TK Virtual records flight information in order to administer pilot activity and verify flights completed for the Virtual Airline.
For flights conducted on the VATSIM network, TK Virtual may process information that is publicly available through VATSIM or made available through services that TK Virtual is permitted to use.
| Information | Purpose |
|---|---|
| Pilot identifier and callsign | Associate the flight with the correct pilot |
| Date of flight | Maintain an accurate chronological activity record |
| Departure and arrival | Record and verify the operated sector |
| Route | Operational record and flight verification |
| Aircraft | Operational and fleet statistics |
| Flight time | Activity records, statistics and pilot progression |
| Network | Identify whether the flight was operated on VATSIM or another supported environment |
TK Virtual does not control personal data processed independently by VATSIM. VATSIM's processing of its members' information is governed by VATSIM's own policies.
7. Third Party Services and Recipients
TK Virtual uses external services where they are necessary to provide Virtual Airline functionality.
These services may include:
- VATSIM for network activity and flight verification
- vAMSYS for Virtual Airline management and flight operations
- Discord for community communication and verification
- Hosting and infrastructure providers
- Email service providers
Personal data is only shared where it is necessary for a relevant service, where the user has requested it, where consent has been provided where required, or where another lawful basis exists.
Third party providers may act as independent controllers for some processing activities and may maintain their own privacy policies.
8. International Data Transfers
Some third party services used by TK Virtual may process information outside Germany or the European Economic Area.
Where the GDPR requires safeguards for an international transfer, TK Virtual relies on the safeguards made available by the relevant service provider, such as an adequacy decision or appropriate contractual safeguards, where applicable.
9. Data Retention
Personal data is kept only for as long as it is reasonably necessary for the purpose for which it was collected, unless a longer period is required or justified.
Membership information may be retained for the duration of membership and for a reasonable period afterwards where required for administration, security or historical records.
Flight records may be retained as historical operational records and for statistics, pilot activity records and Virtual Airline verification purposes.
Technical and security logs are kept only for as long as reasonably necessary for troubleshooting, security and abuse prevention.
Where identifiable information is no longer necessary, it will be deleted or anonymised where appropriate.
10. Data Security
TK Virtual uses reasonable technical and organisational measures to protect personal information against accidental or unlawful destruction, loss, alteration, disclosure and unauthorised access.
Administrative access to personal data is restricted to authorised persons who require access for their role within TK Virtual.
No online service can guarantee absolute security. TK Virtual therefore regularly reviews its systems and access controls where appropriate.
11. Your Rights under the GDPR
Where the GDPR applies, individuals may have the right to:
- Request access to personal data held about them
- Request correction of inaccurate or incomplete data
- Request deletion of personal data where applicable
- Request restriction of processing where applicable
- Object to processing based on legitimate interests where applicable
- Receive certain personal data in a portable format where applicable
- Withdraw consent where processing is based on consent
- Lodge a complaint with a competent data protection supervisory authority
These rights may be subject to conditions and exceptions provided by applicable data protection law.
Requests can be sent to management@tkvirtual.de.
12. Account and Data Deletion
Users may request deletion of personal data by contacting TK Virtual at management@tkvirtual.de.
A deletion request does not necessarily require the deletion of information that TK Virtual is legally required or otherwise permitted to retain.
Where retention of a complete record is not necessary, identifying information may instead be removed or anonymised.
14. Children and Young Users
TK Virtual recognises that Virtual Airline and flight simulation communities may include younger users.
Personal data relating to younger users is handled with particular care. Where applicable law requires consent from a parent or legal guardian for a particular processing activity, TK Virtual will require such consent before relying on that activity.
15. Automated Decision Making
TK Virtual does not currently use personal data to make solely automated decisions that produce legal effects or similarly significant effects on individuals.
Automated technical systems may be used for security, anti-abuse checks, flight processing and operational functionality, but these do not constitute automated decision making of the type described above.
16. Changes to this Privacy Policy
TK Virtual may update this Privacy Policy when its services, systems, processing activities or legal obligations change.
The current version will be published on this page together with the latest revision date.
17. Contact
Questions about this Privacy Policy or requests concerning personal data can be sent to: