ATC-SMS (Air Traffic Control Shift Management System) is an independent software product developed and operated by Ionita Alexandru, Romania ("we", "us"). We are the data controller for the personal data processed through ATC-SMS, under the EU General Data Protection Regulation (GDPR) and Romanian Law 190/2018.
ATC-SMS is not owned, operated or endorsed by any employer or air navigation service provider. An organisation whose staff use ATC-SMS does not control the app or the data in it, unless a separate written agreement says otherwise.
This policy covers the ATC-SMS web application, its iOS and Android apps, and the push notifications they send. ATC-SMS is a planning and scheduling aid. It is not an operational air traffic management system.
We process only what is needed to build and publish rosters and keep users informed about them.
| Category | Examples | Source |
|---|---|---|
| Account data | Name, username and login alias, email address, phone number, date of birth, password hash, role (e.g. controller, sector supervisor, shift supervisor, administrator), cohort membership | Administrator or you |
| Scheduling data | Shift and sector assignments, availability, leave and absence periods, timesheet entries | Administrator, supervisors, you, imported rosters |
| Training and authorisation data | Sector group authorisations and their status, hours worked per sector group, trainee–instructor (OJTI) pairings, remediation status | Administrator, Training Officer, supervisors |
| Notification data | Notification preferences, quiet hours, delivery and read status, push device tokens | You, your device |
| Technical data | IP address, browser or app version, device type, login times, audit log of changes made in the app | Collected automatically |
We do not ask for, and you should not enter, the reason for an absence (for example medical details). ATC-SMS records only that you are unavailable and for which dates.
We do not use advertising trackers, analytics profiling or automated decision-making that produces legal effects for you. Rosters generated by the scheduling engine are always reviewed and published by a human supervisor.
| Purpose | Data used | Legal basis (GDPR Art. 6) |
|---|---|---|
| Creating and managing your account, letting you sign in | Account, technical | Performance of the service you use (6(1)(b)) |
| Building, publishing and changing shift and sector rosters | Account, scheduling, training and authorisation | Performance of the service (6(1)(b)); legitimate interest in accurate, rule-compliant rosters (6(1)(f)) |
| Checking roster eligibility rules (e.g. recency of sector hours, training pairings) | Scheduling, training and authorisation | Legitimate interest in rosters that respect licensing and training rules (6(1)(f)) |
| Sending reminders and alerts | Account, notification | Performance of the service (6(1)(b)); push notifications only with your device permission (6(1)(a)). WhatsApp messages go to the phone number in your account; you can turn them off in notification settings |
| Keeping the app secure, investigating errors and misuse, keeping an audit trail | Technical, audit log | Legitimate interest in security and accountability (6(1)(f)) |
| Meeting legal obligations | Any, as required | Legal obligation (6(1)(c)) |
Where we rely on legitimate interest, you can object at any time (see section 6). We will stop unless we have compelling grounds that override your interests.
We do not sell personal data or share it for marketing. Inside ATC-SMS, what you see about colleagues depends on your role: controllers see published rosters; supervisors and administrators see the data needed to plan them.
We use these service providers, each bound by a data processing agreement:
| Provider | Role | Data | Location |
|---|---|---|---|
| Hetzner Online GmbH | Servers and database | All app data | Germany (EU) |
| WHAPI.Cloud (WhatsApp gateway) and WhatsApp (Meta) | Delivery of notifications by WhatsApp, and roster images posted to the WhatsApp groups of your team | Phone number, notification content (shift and position times, sector names), roster images showing names and assignments | May be outside the EEA (Standard Contractual Clauses) |
| Google (Firebase Cloud Messaging) | Push notification delivery to the iOS and Android apps | Device token, notification content | EU and USA (EU–US Data Privacy Framework / Standard Contractual Clauses) |
| Your browser's push service (e.g. Google, Mozilla, Apple) | Web push delivery on desktop | Push endpoint; message content is end-to-end encrypted | Varies by browser |
| Apple App Store, Google Play | App distribution and updates | Governed by their own privacy policies | Global |
We may disclose data if required by law, a court order or a competent authority. Where data leaves the EEA, we rely on an adequacy decision or Standard Contractual Clauses.
| Data | Kept for |
|---|---|
| Account data | While your account is active. A deactivated account is kept, inactive, so that past rosters and the audit trail stay complete. You can ask us to delete or anonymise it (see section 6) |
| Rosters, timesheets, training and authorisation history | No fixed end date, so eligibility, recency and training history can be checked across years. Deleted on request where we no longer have a reason to keep it |
| Notification delivery log | 90 days |
| Security and audit logs | No fixed end date, so changes to rosters and accounts stay traceable. Deleted on request where we no longer have a reason to keep them |
| Push device tokens | Until you turn off push notifications in notification settings, uninstall the app, or the push service reports the token expired |
Archived cohorts are kept read-only under the same periods.
We protect data with encrypted connections (HTTPS), hashed passwords, role-based access control, per-cohort data separation, regular backups and an audit log of changes. No system is perfectly secure; if a breach is likely to put you at risk, we will tell you and the supervisory authority as GDPR requires.
ATC-SMS uses only strictly necessary cookies and local storage: a session cookie to keep you signed in and stored preferences such as display settings. No advertising or third-party analytics cookies are used, so no cookie consent banner is required.
Under the GDPR you can:
Send requests to gdpr@acc-bucuresti.ro. We reply within one month. Some data, such as published roster history, may need to be kept for the periods in section 5 even after a request.
You can also complain to the Romanian supervisory authority, ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal), at dataprotection.ro, or to the authority in your EU country.
ATC-SMS is intended for professional use and is not directed at anyone under 18.
We may update this policy when the app changes. We will show the new effective date at the top and notify users in the app before material changes take effect.
Contact: Ionita Alexandru, gdpr@acc-bucuresti.ro.