Privacy Policy
Effective date: 28 September 2026
Scope
This Privacy Policy covers the NAVYLA pre-launch website at navyla.app. It does not cover the future NAVYLA mobile application, user accounts, boarding passes, flight data, location or indoor positioning, notifications, subscriptions, or application SDK/API providers. Separate app privacy information will be provided before any application test or launch.
Who is responsible for your personal data?
The controller responsible for personal data processed through this website is:
| Controller | RADU-IULIAN TODEROIU, acting as a natural person |
| Country | Belgium |
| Address | Avenue Henri Conscience 94, 1140 Evere, Belgium |
| Privacy contact | privacy@navyla.app |
| General contact | contact@navyla.app |
“NAVYLA”, “we”, “us”, and “our” refer to the controller identified above in connection with this pre-launch website.
Personal data we collect
Early Access requests
If you join NAVYLA Early Access, we collect your email address and the responses you provide in the Early Access form, including your flight frequency, the airport situations you find most stressful, whether you have nearly missed a flight because of airport confusion, how useful you believe NAVYLA would be at the airport, and your preferred airport where provided. We also retain the consent record associated with the submission and may retain the date and time, language or source form, and other submission metadata needed to administer the Early Access list and demonstrate your request.
Contact requests
If you contact us through the website, we collect your name, email address, subject, and message, together with ordinary email transmission information such as the submission time and message headers. Please do not send special-category data, financial information, identity documents, health information, or other sensitive information through the contact form.
Technical and security data
When you visit the website, the website and hosting infrastructure may process technical information needed to deliver and protect the service, such as your IP address, browser and device information, requested pages and files, date and time, referring page, error and diagnostic data, and security-related events. The exact data available in logs depends on Hostinger and the current website configuration.
Cookies and language preference
The website currently uses hcdn, a session cookie supporting content delivery, security, and reliable operation, and pll_language, which remembers the language selected on the website for up to one year. Details are provided in the Cookie Policy.
Google Fonts
The website currently requests the Roboto typeface from Google Fonts. When your browser requests that resource, technical request data such as your IP address, browser information, requested resource, and time of request may be transmitted to Google. We do not use this request for our own analytics or advertising.
Why we use personal data and our legal bases
| Activity | Purpose and legal basis |
| Early Access | To register and administer your Early Access request; send the limited testing-availability, invitation, or launch communication you requested; and analyse Early Access responses to understand traveller needs, product priorities, and airport demand. We may create aggregated or de-identified statistics for product planning, business planning, investor or partner presentations, and concept validation. Legal basis: your consent, Article 6(1)(a) GDPR. |
| Contact enquiries | To read, route, answer, and manage your enquiry. Legal basis: our legitimate interest in communicating about NAVYLA, Article 6(1)(f) GDPR. Article 6(1)(b) may apply where your request concerns steps before a possible contract. |
| Website delivery | To provide pages and language functionality, diagnose errors, maintain availability, and protect the website. Legal basis: our legitimate interests in operating a reliable and secure website, Article 6(1)(f) GDPR. |
| Legal compliance | To comply with legal obligations and to establish, exercise, or defend legal claims. Legal basis: Article 6(1)(c) or Article 6(1)(f) GDPR, depending on the situation. |
We do not use Early Access information for a general newsletter, unrelated advertising, or third-party marketing. We do not sell personal data. We do not use personal data from this website for automated decision-making or profiling. Where Early Access results are used in a business plan, pitch deck, partner discussion, or other external material, we use aggregated or de-identified statistics and do not publish your email address or present your individual response as an identified person.
Is providing the data mandatory?
Joining Early Access is optional. To submit the current Early Access form, we require your email address, the survey questions marked as required, and the required consent acceptance. The preferred-airport field is optional. These responses help us administer Early Access and assess traveller needs, product priorities, and airport-specific demand. Contacting us is optional, but we need an email address and sufficient message content to respond.
Who receives the data?
Access is limited to the controller and service providers that support the website and email delivery, to the extent needed for their tasks. Current relevant providers include:
- Hostinger International Ltd., for website hosting, content delivery, security, backups, and domain email services. Hostinger processes customer data under its Data Processing Addendum.
- Google, for Google Sheets used to store and analyse Early Access responses and for the external Google Fonts request described above. Google processes the information it receives under its applicable terms and data-protection arrangements.
WordPress, Contact Form 7, Polylang, Flamingo, and GSheetConnector are software components used on the website. Contact Form 7 processes form submissions and sends configured email notifications. Flamingo stores a copy of submitted form data in the WordPress database hosted with Hostinger. GSheetConnector transmits the configured Early Access fields to a Google Sheet used for centralisation, normalisation, and statistical analysis. Access to these records is restricted to the controller and authorised service accounts used for NAVYLA administration.
We may also disclose information where required by law, a competent authority, or a court, or where reasonably necessary to protect legal rights and website security.
Hosting locations and international transfers
The primary website server is currently located in the Netherlands, and the configured backup location is Lithuania. Both locations are within the European Economic Area. Hostinger or its subprocessors may process limited data in other countries. Early Access responses stored in Google Sheets, and the Google Fonts request, may involve processing by Google in countries outside the EEA. Where GDPR transfer restrictions apply, we rely on an applicable adequacy decision or appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, as relevant to the provider and transfer.
How long we keep the data
| Data | Retention |
| Early Access | Until the relevant invitation, testing-availability, or launch communication has been completed, you withdraw consent, or 24 months after sign-up, whichever occurs first. This retention rule applies to active Early Access copies held in the operational mailbox, WordPress/Flamingo, and Google Sheets. A limited suppression or consent record may be retained where necessary to respect your withdrawal or demonstrate compliance. |
| Contact enquiries | Normally for up to 12 months after the last substantive communication. Relevant correspondence may be retained longer where necessary for a legal obligation, dispute, or the establishment, exercise, or defence of legal claims. |
| Technical and security logs | Only for the period reasonably needed for website delivery, diagnostics, abuse prevention, security, and the configured hosting retention. Logs are not intentionally kept longer than necessary. |
| Backups | Residual copies may remain until the normal backup cycle overwrites them. Access is restricted and backups are used only for restoration, security, or legal purposes. |
Your rights
Subject to the conditions and exceptions in the GDPR, you may request:
- access to personal data we hold about you;
- correction of inaccurate or incomplete data;
- erasure of your data;
- restriction of processing;
- data portability where processing is based on consent or contract and carried out by automated means;
- objection to processing based on legitimate interests; and
- withdrawal of consent at any time, without affecting processing already carried out lawfully before withdrawal.
To exercise a right or withdraw Early Access consent, email privacy@navyla.app. We may ask for information reasonably necessary to verify your identity. We normally respond within one month, subject to the extensions and limitations permitted by law.
You also have the right to lodge a complaint with the Belgian Data Protection Authority or another competent supervisory authority. Lodge a complaint with the Belgian Data Protection Authority.
Security
We use reasonable technical and organisational measures appropriate to the current website and the nature of the data, including secure transport, access controls, account protection, software maintenance, and hosting security features. No method of transmission or storage is completely secure, so absolute security cannot be guaranteed.
Children
The pre-launch website and Early Access list are not intentionally directed to children under 16. If you believe a child has submitted personal data, contact privacy@navyla.app so that we can assess and, where appropriate, delete it.
External links
The website may link to websites or services operated by third parties. Their privacy practices are governed by their own notices, not this Privacy Policy.
Changes to this Privacy Policy
We may update this Privacy Policy when the website, providers, or legal requirements change. The current version will be posted on navyla.app with a revised effective date. Material changes affecting an existing consent will be handled as required by law.
Contact
| Privacy requests | privacy@navyla.app |
| General enquiries | contact@navyla.app |
| Postal address | Avenue Henri Conscience 94, 1140 Evere, Belgium |