Last updated: 22 July 2026
Fly High English is an online aviation English training and assessment platform for pilots, controllers, and crew. We’re based in Ireland and we’re committed to respecting your privacy.
Personal data is any information which relates to an individual. This Privacy Policy explains what personal data we collect, why we collect it, who we share it with, and the rights you have over it.
Whenever we say ‘we’ in this policy, we mean Fly High English, the data controller for the processing activities described here. Reach us at support@flyhighenglish.com for anything privacy-related.
1. What we collect
You give us: your name, email address, aviation role, country, and membership level when you create an account. Paid subscribers also provide billing details. When you use our speaking or assessment tools, you provide voice recordings or written responses.
We collect automatically: usage activity (which content you access, time spent), device and browser information, and your IP address.
We don’t: buy data from third-party brokers, pull data from social networks, or collect anything we don’t need to run the service.
2. How we use it
To run your subscription: delivering content, processing payments, and sending receipts and account notifications.
To power assessments: your recordings and written responses are sent to AI providers that score your proficiency and generate your personalised feedback.
To improve the product: we analyse anonymised, aggregated usage patterns. You’re never individually identifiable in this analysis.
For security: detecting fraud and protecting the platform against abuse.
What we don’t do: we don’t sell your data, use it for advertising, or allow any of our providers to use your recordings or responses to train their general AI models.
3. Legal basis for processing
We need a legal justification (‘lawful basis’) each time we process personal data. Here is the basis we rely on for each type of processing:
| Purpose | Lawful basis |
| Running your subscription, delivering content, processing payments | Contract performance |
| Speaking Assessment and Level Check processing | Consent — explicit, given per submission |
| Newsletter and marketing emails | Consent — opt-in |
| Analytics cookies (Jetpack Stats) | Consent — opt-in via cookie banner |
| Security, fraud prevention, anonymised product analytics | Legitimate interests |
| Retaining financial records | Legal obligation |
We rely on legitimate interests only where those interests are not overridden by your rights. You can object to any processing based on legitimate interests by emailing support@flyhighenglish.com.
4. AI-powered assessments
Our platform includes two AI-powered tools: the Speaking Assessment (available to Plus and Pro members) and the Level Check (open to everyone). Here’s how each works.
Speaking Assessment. When you choose to record a spoken answer, your recording is transmitted securely to our AI providers, transcribed, and scored. The feedback and your score are saved to your account so you can track progress over time.
Level Check. A short written placement check. We store your answers, skill scores, overall band, and (if provided) your email address so we can send you your result and a study plan. Incomplete anonymous attempts are automatically deleted after approximately 2 days.
Our AI providers are OpenAI (speech-to-text transcription and pronunciation analysis) and Anthropic (written feedback and rating). We send them only your recording, transcript, and selected first language — not your name, email, or account details. Under both providers’ API terms, data submitted via the API is not used to train their general models.
Consent. We ask for your explicit confirmation before each assessment submission. You can withdraw consent at any time by emailing legal@flyhighenglish.com — this disables the AI tools but doesn’t affect the rest of your account.
Assessment scores are indicative practice feedback — not an official ICAO proficiency rating. Official endorsements require an authorised examiner.
5. Who we share data with
We share your data only with the providers we need to operate the platform.
| DreamHost | our web hosting and server infrastructure provider (servers located in the United States). |
| Stripe | payment processing. Your card details go directly to Stripe; we never see or store them. |
| Automattic (Jetpack) | site services including anonymised analytics (Jetpack Stats) and comment spam filtering (Akismet). |
| MailerLite | email delivery for receipts, account notifications, and the newsletter (if you’ve subscribed). |
| OpenAI and Anthropic | AI processing for speaking assessments, as described in Section 3. |
| Professional advisers | our lawyers and accountants, under strict confidentiality, where genuinely necessary. |
| Authorities | if required by law, court order, or a regulatory authority such as the Irish Revenue Commissioners. |
| Advertising partners | We partner with advertising providers to serve you relevant advertisements in relation to our products and services, including sharing customer data with them to inform and refine our marketing, advertising and general business strategy. In order to collect information about your activities to tailor those advertisements, we set cookies (with your consent, which you can remove at any time through the functionality on this website). |
| User experience, service design and market research agencies | We partner with user experience, service design and market research agencies which assist us with the improvement and optimisation of our products and services, along with other market research projects. |
We do not sell your data or share it with advertisers or data brokers. If Fly High English is ever sold or merged, your data would transfer to the new owner under the same obligations — and we’d notify you before it happened.
6. International data transfers
Some of our providers are based outside the EEA. Our hosting provider (DreamHost) stores data on servers in the United States. Where we transfer data internationally, we use EU Standard Contractual Clauses approved by the European Commission to ensure your data receives equivalent protection.
7. What are my rights
You have several rights under data protection laws. Some of these rights are subject to exceptions. You can exercise your rights through the details above.
| Right to be informed | You have a right to be told about how and why we process your information. We do that through this Privacy Policy and other information we may make available. |
| Right to access | You have a right to access that information we hold on you. This right does not extend to accessing information on other people or businesses. |
| Right to deletion | You have a right to have information about you deleted or erased, unless an exception applies. In some cases, we need to retain information due to legal or regulatory requirements. This is also known as the ‘right to be forgotten’. |
| Right to restrict | You have a right to restrict how we use your information in certain circumstances, such as where you think it is inaccurate. |
| Right to object | You have a right to object to the processing of your information based on Legitimate Interests, except where we have ‘compelling interests’ which override that. An example would be where we consider the processing necessary to ensure the safety of the financial services sector. |
| Right to withdraw your consent | You have a right to withdraw your Consent at any time if we rely on this as our legal basis. If you do this, we will stop further processing the relevant information on that basis, but may rely on another basis.We do not routinely rely on Consent for any processing activity, except where we need to under ePrivacy law (in relation to cookies and certain electronic marketing activities). |
| Right to not be subject to an automated decisions without human intervention which have certain effects | You have a right not to be subject to automated decisions which have ‘legal effects’ or ‘similarly significantly affect’ you (such as the denial of a financial service), if a human does not intervene in that decision. |
You also have the right to raise a complaint with us or the relevant supervisory authority, as outlined in Section 2 above.
To help us investigate your complaint, please provide:
- Your name, contact details, and merchant identification (if you have one).
- Full details of your complaint.
If you are submitting a complaint on someone’s behalf, we will ask you to provide proof of authority to act on that person’s behalf. In some cases we may also ask you to provide proof of identity if we are unable to verify your identity from our existing records.
We will acknowledge your complaint within 30 days. We aim to resolve all complaints without undue delay.
To close your account entirely, go to Settings on the platform.
If you think we’ve mishandled your data, you can complain to the Irish Data Protection Commission at www.dataprotection.ie.
8. How long we keep data
We delete or anonymise data as soon as we no longer need it:
| Data | How long we keep it |
| Account & profile | While your account is active + 3 years after closure |
| Assessment audio recordings | 60 days — then permanently deleted by an automated process |
| Assessment transcripts & reports | Life of account (so you can track your progress), then anonymised |
| Level Check results | Life of account; incomplete anonymous attempts deleted after ~2 days |
| Payment records | 7 years (Irish tax law) |
| Server & access logs | 90 days |
9. Cookies
Essential cookies keep you logged in and are necessary for the platform to work. Functional cookies remember your preferences. Analytics cookies (Jetpack Stats by Automattic — opt-in only) help us understand platform usage using anonymised data only.
We don’t use advertising or behavioural tracking cookies. Manage your preferences using the cookie settings link in the platform footer. For more detail, see our Cookie Policy at www.flyhighenglish.com/cookies.
10. Security
Your data is encrypted in transit (TLS 1.2+) and at rest. Production access requires multi-factor authentication and is restricted to authorised staff. Our AI providers are contractually required to meet equivalent security standards. Assessment audio files are stored under randomly generated filenames and served only through authenticated, access-controlled links.
If a breach affects you, we’ll notify the Irish Data Protection Commission within 72 hours and contact you directly if there’s a real risk to your rights.
11. Under 18s
Fly High English is for aviation professionals. We don’t knowingly collect data from anyone under 18. If you believe a minor has an account, email support@flyhighenglish.com and we’ll remove it immediately.
12. Changes to this policy
We’ll notify you by email before any significant changes take effect. The current version is always at www.flyhighenglish.com/privacy.
Questions? support@flyhighenglish.com · We aim to respond within 2 business days.
Regional notes
EU / EEA / UK (GDPR). We process your data on the bases of contract performance (running your subscription), consent (AI assessment processing, optional analytics and marketing), and legitimate interests (security, fraud prevention, anonymised analytics). You have the additional rights to data portability and to object to processing based on legitimate interests. You may lodge a complaint with the Irish Data Protection Commission (www.dataprotection.ie).Brazil (LGPD). We process your data under the equivalent bases in Law 13,709/2018. You have all the rights in Article 18 of the LGPD, including the right to anonymisation, blocking, or deletion of unnecessary or excessive data, and the right to know with whom we have shared your data. You also have the right to request human review of any automated decision that affects you. You may lodge a complaint with the ANPD at www.gov.br/anpd. Transfers outside Brazil are made under the mechanisms permitted by LGPD Article 33.