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Privacy Policy

Last updated: 27 April 2026 · Data controller: DRS SPV 1 LIMITED, England & Wales

Our commitments✓ Logbooks permanently deleted after analysis✓ We never sell your data✓ Encrypted in transit and at rest✓ UK GDPR compliant

This Privacy Policy explains how DRS SPV 1 LIMITED ("ZuluHi", "we", "us", "our") collects, uses, stores, and protects your personal data when you use our Part-66 logbook compliance analysis service. We are committed to handling your data responsibly and in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1. Who We Are

DRS SPV 1 LIMITED is the data controller for personal data collected through our website and platform. We are registered in England and Wales (Company No. 15409253).

If you have any questions about how we handle your data, please contact our data protection point of contact at team@zuluhi.com.

2. What Data We Collect

We collect the following categories of data:

CategoryData collectedHow collected
Account dataEmail address, password (hashed), account creation dateWhen you register
Transaction dataPlan purchased, amount, date, Stripe payment referenceWhen you make a purchase
Configuration dataRegulatory framework selected (EASA/UK CAA), licence category, training route, licence typeWhen you configure your analysis
Logbook documentsPDF files you upload (temporarily — see Section 4)When you upload your logbook
Report dataYour generated compliance report and analysis resultsGenerated automatically post-upload
CommunicationsMessages sent via support email or Q&A (Pro/Expert plans)When you contact us
Technical dataIP address, browser type, device type, pages visited, session durationAutomatically via cookies and server logs

We do not collect payment card details — these are handled directly and securely by Stripe, our payment processor. We receive only a transaction reference.

3. How We Use Your Data

We use the data we collect for the following purposes:

To create and manage your ZuluHi account
To process your payment and issue your compliance report
To generate your Part-66 compliance analysis and action plan
To provide Q&A and expert review support (Pro and Expert plans)
To communicate with you about your report, account, or service updates
To detect and prevent fraud, misuse, or security incidents
To comply with our legal and regulatory obligations
To improve the accuracy of our analysis engine using anonymised, aggregated data only — never your identifiable logbook content

We will never use your data for unsolicited marketing without your explicit consent.

4. Logbook Documents — Special Category

We treat your logbook documents as particularly sensitive. Here is exactly what happens to your files from the moment you upload them to the moment they are destroyed.

Your logbook is encrypted in transit using TLS 1.2 or higher
It is encrypted at rest using AES-256 encryption while being processed
It is processed exclusively to generate your compliance report — for no other purpose
It is permanently and irreversibly deleted from our servers immediately after your report has been generated
We do not retain copies of your logbook, share it with third parties, or use its contents to train AI models in any identifiable form
Only your generated compliance report is retained — accessible in your account

You are responsible for ensuring you have the legal right to upload any documents you submit. By uploading a logbook, you confirm that it is your own or that you have the explicit authorisation of the licence holder.

5. Legal Basis for Processing

Under UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following:

Processing activityLegal basis
Account creation and managementContract — necessary to provide the Service
Payment processing and issuing reportsContract — necessary to fulfil your purchase
Logbook processing and report generationContract — the core service you have paid for
Fraud prevention and securityLegitimate interests — to protect our platform and users
Improving our analysis engine (anonymised data only)Legitimate interests — to improve accuracy of the Service
Compliance with legal obligationsLegal obligation
Marketing communications (if opted in)Consent

6. Data Sharing

We do not sell your personal data. We share it only with the following categories of trusted third parties, and only to the extent necessary to provide the Service:

Stripe — payment processing. They receive transaction data only, not your logbook or report
Cloud infrastructure providers — for hosting, storage, and processing (data held within the UK or EEA)
Email service providers — for transactional communications (account confirmations, report delivery notifications)
Expert reviewers — for Pro and Expert plan customers, your configuration data and report are shared with our certified Part-66 reviewer. Logbook content is not shared with reviewers directly — they access only the extracted report data

All third-party processors are bound by data processing agreements in compliance with UK GDPR. We require that they process your data only for the specified purposes and maintain appropriate security measures.

We may disclose your data to law enforcement or regulatory authorities where required to do so by law.

7. International Data Transfers

We aim to keep your data within the UK and European Economic Area (EEA). Where we use service providers based outside the UK/EEA, we ensure appropriate safeguards are in place, such as UK International Data Transfer Agreements (IDTAs) or standard contractual clauses.

If you have questions about specific transfers, please contact team@zuluhi.com.

8. Data Retention

Data typeRetention period
Logbook documents (uploaded files)Deleted immediately after report generation
Compliance reportsRetained in your account indefinitely — accessible until you close your account
Account data (email, preferences)Retained while your account is active + 30 days after closure
Transaction records7 years (required by UK financial regulations)
Support communications3 years from last contact
Technical/server logs90 days

When retention periods expire, data is securely and permanently deleted.

9. Your Rights Under UK GDPR

As a UK resident, you have the following rights regarding your personal data:

→Right of access

Request a copy of the personal data we hold about you

→Right to rectification

Ask us to correct inaccurate or incomplete data

→Right to erasure

Request deletion of your data where there is no lawful reason to retain it

→Right to restriction

Ask us to limit how we use your data in certain circumstances

→Right to portability

Receive your data in a structured, machine-readable format

→Right to object

Object to processing based on legitimate interests or for direct marketing

→Right to withdraw consent

Where processing is based on consent, you can withdraw it at any time

→Rights re: automated decisions

Request human review of decisions made by automated means that significantly affect you

To exercise any of these rights, contact us at team@zuluhi.com. We will respond within one calendar month. We may need to verify your identity before processing your request.

10. Cookies

We use cookies and similar technologies to make our platform work and to understand how it is used. The cookies we use fall into the following categories:

Essential cookies — required for the platform to function (authentication, session management). Cannot be disabled.
Analytics cookies — help us understand how users navigate the platform so we can improve it. Used in anonymised, aggregated form only.
Preference cookies — remember your settings, such as language preference.

We do not use advertising or tracking cookies. You can manage cookie preferences in your browser settings. Disabling non-essential cookies will not affect your ability to use ZuluHi.

11. Children

ZuluHi is not directed at children under the age of 18. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, please contact us at team@zuluhi.com and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify you by email and update the "Last updated" date at the top of this page.

We encourage you to review this Policy periodically. Continued use of ZuluHi after any changes constitutes acceptance of the updated Policy.

13. Contact & Complaints

If you have any questions about this Privacy Policy or how we handle your data, please contact us:

DRS SPV 1 LIMITED

Registered in England & Wales · Company No. 15409253

Data enquiries: team@zuluhi.com

Website: zuluhi.com

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:

Information Commissioner's Office

Website: ico.org.uk

Helpline: 0303 123 1113

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