ข้อมูลทางกฎหมาย

1. SCOPE

1.1. This Notice explains how information is processed when you use the LT Flights application for Android, iOS, and compatible mobile platforms, including its server features, flight search, advertising, and related online services (the “App”).

1.2. It does not govern ticket sellers, advertisers, app stores, system calendars, cloud providers, or other independent third-party services. Their own terms and privacy notices apply when you visit them or provide information to them.

2. CONTROLLER AND CONTACT

2.1. Controller and App developer: Igor Vladimirovich Repin (Репин Игорь Владимирович), Republic of Bashkortostan, Russian Federation (the “Controller”). Public developer name: Igor Repin in English and Игорь Репин in Russian. Both names refer to the same Controller. The App's default language is English, and its default name is LT Flights. The App may have localized names in supported languages, such as LT Перелёты in Russian and LT 航班 in Simplified Chinese. Additional supported languages and localized names may be introduced; all such names refer to the same App.

2.2. Privacy and support inquiries: support@luntan.pro.

2.3. Russian Register of Personal Data Operators: No. 2-26-060086, Order No. 143 dated August 19, 2026. Processing commencement date: August 24, 2026.

3. HOW THE APP WORKS

3.1. The App does not require an account or registration. Flight cards, reminders, notes, and files selected by you are stored on your device by default.

3.2. The Controller does not sell airline tickets or travel services and is not an airline, travel agency, or insurer. The Controller does not receive passenger identity, payment, or complete booking details from a seller. Offer search and seller referrals are affiliate services, and the Controller may receive compensation without increasing your price.

3.3. Certain online features process limited information off the device: offer search, advertising, public-data retrieval, and, after separate consent, AppMetrica Push, technical crash diagnostics, and server-delivered flight-status notifications. The Controller does not use AppMetrica to collect custom user events, screen views, funnels, or marketing profiles.

4. DATA STORED LOCALLY

4.1. Your device may store a flight number and date, route, airports, airline, times, terminal and gate, reminders, notes, a reference to or copy of a selected document, local notification history, and App preferences.

4.2. The App uses this information to display flight cards, work offline, provide reminders, export calendar events, and perform other requested functions. It is not sent to the Controller's server except for the limited watched-flight fields used when you enable server notifications under Section 7.

4.3. Local information remains until you delete it, clear the App's data, or uninstall the App. A calendar copy may remain and be synchronized by your calendar provider and must be managed separately.

5. FLIGHT SEARCH AND TRAVELPAYOUTS

5.1. Flight search uses Travelpayouts SDKs and interfaces. By selecting “Search,” you initiate transmission to Travelpayouts and relevant providers of the origin, destination, dates, passenger count, cabin class, currency, language, filters, selected offer, IP address, and App, device, and referral information.

5.2. After selecting an offer, you continue to an airline, agency, or other seller and provide passenger, contact, and payment details directly to that seller. The Controller does not receive those details and cannot manage your booking, payment, or refund.

5.3. Travelpayouts independently determines processing within its platform. Its current notice is available at https://support.travelpayouts.com/hc/en-us/articles/360004121052-Privacy-Policy.

5.4. The Controller does not retain the raw search request in its own server database and does not receive Travelpayouts' raw technical logs. The Controller may receive affiliate statistics about referrals and qualifying actions and related compensation, but does not use this information to identify a passenger.

6. APPMETRICA PUSH AND CRASH DIAGNOSTICS

6.1. After your separate affirmative consent, AppMetrica may process a pseudonymous installation identifier, push token, technical device, operating-system, App-version, and session information, as well as errors, crashes, application-not-responding events, and diagnostic data. The Controller's purposes are AppMetrica Push, correction of technical errors, and improved stability.

6.2. Before consent, AppMetrica data transmission, automatic sessions, crash collection, and push processing are disabled. Flight-card, note, and document contents, custom user events, screen names, and funnel parameters are not sent to AppMetrica. Declining does not restrict local App functions. You may withdraw consent in Settings. Withdrawal stops future transmission but does not affect prior lawful processing or automatically erase information that the provider is legally permitted or required to retain.

6.3. For the Russian service environment, the AppMetrica recipient and service provider is YANDEX LLC, 16 Leo Tolstoy Street, Moscow 119021, Russian Federation. In another jurisdiction, the applicable recipient may be another Yandex group entity identified in the service's current documents. See https://yandex.com/legal/confidential/, https://yandex.com/legal/metrica_agreement/, and https://appmetrica.yandex.com/docs/en/data-security/gdpr.

7. FLIGHT-STATUS NOTIFICATIONS

7.1. This feature is enabled only after separate data-processing consent and after you turn on server notifications. The operating system's notification permission is requested separately.

7.2. The feature processes a random installation identifier, locale and notification settings, the APNs or FCM transport type and token, HMS details on supported devices, and the watched flight number, date, route, scheduled times, time zones, airline, and necessary operational flight fields.

7.3. The Controller's server is located in the Russian Federation. It receives the watched-flight fields, requests public operational information from a flight-data provider, and prepares a notification. The flight-data provider does not receive your token, installation identifier, notes, documents, or passenger identity.

7.4. A push message contains only public operational information needed for the update: flight number and date, route, status, time, terminal, gate, check-in desk, or baggage belt. The message content does not by itself identify a passenger, but the delivery token and its association with a watched flight are treated as personal data because they can be associated with a device.

7.5. For delivery, the minimal message, push token, and routing data are processed by AppMetrica Push and Apple Push Notification service or Firebase Cloud Messaging. Huawei Push Kit may be used on compatible devices; its current configuration selects the Russian processing region. The notice described in Section 11.2 applies only to APNs and FCM.

7.6. You may stop delivery or separately withdraw consent and initiate deletion of server data under Settings → Legal information and privacy → Consent to personal data processing. Disabling the operating system's notification permission prevents display but is not by itself a deletion request.

8. ADVERTISING

8.1. In the Russian Federation, advertising is provided only through the Yandex Advertising Network. AppMetrica is not an advertising network; its limited use is described in Section 6. In other countries, advertising may be provided through Appodeal, BidMachine, Yandex Ads, AppLovin, AppLovin MAX, Bidon, Unity Ads, IAB components, the Sentry diagnostic component, and other Appodeal demand sources when their applicable requirements are met.

8.2. Advertising SDKs may process an IP address, advertising and other device identifiers, device model and characteristics, operating system, language, time zone, connection and mobile-network information, App information, impressions, clicks, placements, performance, diagnostics, fraud-prevention signals, and consent status. If you grant the App location permission and access is not restricted by SDK settings and applicable consent, advertising providers may receive approximate or precise location.

8.3. Appodeal provides its own consent and privacy-options mechanism in the countries it covers. The form's availability, choices, and effects depend on country, applicable law, platform settings, and SDK version. Opting out of personalization does not disable all ads or all technical processing necessary to deliver, measure, and protect advertising.

8.4. On iOS, App Tracking Transparency authorization is requested immediately before an identifier would be used for cross-app tracking. Declining does not restrict core App functions and does not prevent non-personalized advertising.

8.5. Appodeal documents and controls:

- privacy policy: https://appodeal.com/privacy-policy/;

- public demand-source list: https://appodeal.com/ad-demand-sources/;

- personalization opt-out information: https://appodeal.com/sdk-opt-out/.

8.6. Yandex Privacy Policy: https://yandex.com/legal/confidential/. International advertising is also governed by https://yandex.com/legal/international_ads_privacy_policy/en/.

9. LOCATION, MAPS, CALENDAR, AND EXTERNAL LINKS

9.1. With separate operating-system permission, precise location is used to calculate your distance from an airport. The Controller does not store the coordinates on its server. Possible advertising-SDK access is described separately in Section 8.

9.2. Opening a map sends style and tile requests to OpenFreeMap and its infrastructure. The network address and viewed map area may indicate an approximate location. See https://openfreemap.org/privacy/ and https://openfreemap.org/tos/.

9.3. With permission, the App may create or update an event in the system calendar. The Controller does not upload your calendar, but a calendar account selected on your device may synchronize the event under its own terms.

9.4. When you open an airline, airport, advertiser, seller, or partner site, that recipient receives ordinary network information and independently processes anything you provide after leaving the App.

9.5. If you email support@luntan.pro, the Controller processes the sender address, name or alias, message, voluntarily attached files, date, time, and technical headers to respond, provide support, handle a complaint, and protect legal rights. Separate consent is not required to prepare the response you requested.

10. LEGAL BASES

10.1. The legal basis is determined separately for each operation: performance of an agreement or steps you request for selected functions and inquiry responses; consent for AppMetrica Push, crash diagnostics, server notifications, and operations where consent is required; compliance with law; and legitimate interests in security and legal protection where those interests are not overridden by your rights. Under Russian law, the applicable basis is determined under Article 6(1) of Federal Law No. 152-FZ. Where the GDPR or UK GDPR applies, it is determined under Article 6(1).

10.2. Consent is used for AppMetrica, server notifications, and advertising operations where required by law or platform rules. Consent is not inferred merely from installing or continuing to use the App.

11. INTERNATIONAL TRANSFERS

11.1. Notification delivery through APNs and FCM involves transfers to the United States to Apple Inc. and Google LLC. The transfer consists of a push token, device-routing details, and the minimal notification text described in Section 7.

11.2. The Russian data authority completed its review of cross-border transfer Notice No. 100391496 on August 21, 2026; its status is “Completed,” and the transfer was permitted without restrictions. That notice covers APNs and FCM and does not automatically extend to other purposes or recipients.

11.3. Your decision to continue to a foreign seller or other external service is an independent user action. Further processing is determined by the selected recipient.

12. RETENTION

• local cards, files, reminders, and settings: until you delete them, clear App data, or uninstall;
• watched flights on the Controller's server: until removed from synchronization, the feature is disabled, or the departure date is more than four days old;
• inactive installation state: up to 180 days after the last synchronization if there are no active watched flights;
• flight-data technical events and push-delivery results: up to 30 days;
• synchronization diagnostics: up to 7 days;
• minimal consent and deletion evidence that excludes flight contents and tokens: three years after the relevant processing ends, unless law requires otherwise;
• ordinary support correspondence: up to 12 months after it ends; complaints, disputes, and necessary evidence: until the applicable legal-protection period expires, ordinarily no more than three years;
• independent-provider information: under each provider's rules and settings.

13. RECIPIENTS AND SECURITY

13.1. Depending on the feature, recipients may include the Controller's hosting provider in the Russian Federation, AppMetrica, Apple APNs, Google FCM, Huawei Push Kit, Travelpayouts, Appodeal, Yandex and enabled advertising partners, map providers, the selected seller, the system calendar, and authorities where legally required.

13.2. The Controller uses access restrictions, secure connections, data minimization, separate technical identifiers, software updates, backups, operation logs, deletion schedules, and other legal, organizational, and technical safeguards appropriate to the risk. No Internet transmission can be guaranteed absolutely secure.

14. YOUR RIGHTS AND DELETION

14.1. Subject to applicable law, you may request information, correction, restriction, deletion, or termination of processing; withdraw consent; and complain to a data-protection authority or court.

14.2. You can delete LT Flights server data in App Settings without creating an account. You may also email support@luntan.pro. The Controller will request only the minimum technical details needed and will not request a passport or ticket unless legally necessary.

14.3. Deleting Controller server data does not delete local cards or files, system-calendar events, or information independently controlled by a seller, Travelpayouts, advertising provider, or platform service. Use the relevant provider's controls or contact channel for those records.

15. AGE AND CHANGES

15.1. The App is intended for users aged 18 and older and is not a child-directed app. A person under 18 should use it only with a parent or legal guardian where applicable law permits.

15.2. This Notice may change when features, providers, or laws change. The Russian original is published at https://luntan.pro/ru/legal/flights-privacy/ with its version number and effective date. The English translation is available at https://luntan.pro/legal/flights-privacy/ and the Simplified Chinese translation at https://luntan.pro/zh3/legal/flights-privacy/ . Material changes will also be communicated in the App when required.