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Privacy Policy

Aeromagija Design Center (UAB Budivnika, based in Lithuania, hereinafter "The Company," "We," "Us") respects your privacy and is committed to protecting your personal data. This policy explains how we collect, use, and process the personal information we receive from you when you use our services, including design orders and investment/donation activities, in compliance with the General Data Protection Regulation (GDPR).

 

1. Data Controller and Contact Information

 

Data Controller: UAB Budivnika

Address: Skroblu 25-118, Vilnius, Lithuania]

Email: avmpilot@gmail.com

Phone: +370 66 517 573

 

2. The Data We Collect and the Purpose

 

We process personal data based on the service you require.

Data CategoryData Elements CollectedPurpose of ProcessingLegal Basis (GDPR)

A. Service DataName, Email, Phone Number, Communication Records.To provide design services, fulfill orders, manage accounts, and communicate project status.Contractual Necessity

B. Payment DataBilling address, payment method details (not stored directly; handled by secure payment processor).To process payments for design stages and collect donations/investments.Contractual Necessity

C. Investment/KYC Data (Crucial)Full Legal Name, Residential Address, Nationality, Official ID/Passport Copy, Bank Account Details, Tax ID.To meet legal obligations (KYC/AML) and to execute the formal Investment Agreement and Shareholders’ Agreement (as outlined in our Terms & Conditions).Legal Obligation & Contractual Necessity

D. Technical DataIP address, browser type, location, device information.Website analytics, security, and performance improvement.Legitimate Interest

 

3. Legal Basis for Processing Your Data

 

We rely on the following legal bases under the GDPR to process your personal data:

  • Contractual Necessity: Processing is necessary to perform a contract for our design services (A and B).

  • Legal Obligation: Processing is required to comply with a legal obligation, particularly financial regulations, anti-money laundering (AML) laws, and know-your-customer (KYC) requirements related to investments (C).

  • Legitimate Interest: Where necessary for running our business and protecting our systems (D).

  • Consent: We will specifically ask for your consent for marketing communications, if any.

 

4. How We Share Your Personal Data

 

We may share your data with the following third parties only when necessary for our operations:

  • Payment Processors: To securely process payments for our services.

  • Legal & Financial Advisors: To execute the Investment Agreement, establish the Project Company (NewCo), and ensure legal/tax compliance in Lithuania (applies specifically to Investment/KYC Data).

  • IT Service Providers: For hosting, maintenance, and security of our systems.

We do not sell your personal data to any third parties for marketing purposes.

 

5. International Data Transfers

 

As our operations are based in the European Economic Area (EEA), we primarily store and process data within the EEA. If we must transfer data outside the EEA, we ensure that a legally compliant transfer mechanism is in place (e.g., standard contractual clauses or adequacy decisions).

 

6. Data Retention

 

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purpose of satisfying any legal, accounting, or reporting requirements.

  • Service Data (A): Retained for the duration of the contractual relationship plus a period required by the statute of limitations.

  • Investment/KYC Data (C): Retained for the duration of the Investment/Shareholders' Agreement and for a mandatory minimum period, typically 10 years, as required by Lithuanian and EU financial and anti-money laundering laws.

 

7. Your GDPR Rights

 

Under the GDPR, you have the following rights regarding your personal data:

  • The Right to Access: The right to request copies of your personal data.

  • The Right to Rectification: The right to request that we correct any information you believe is inaccurate or incomplete.

  • The Right to Erasure ("Right to be forgotten"): The right to request that we erase your personal data, subject to legal constraints (e.g., we cannot erase KYC data required by law).

  • The Right to Restrict Processing: The right to request that we limit the way we use your data.

  • The Right to Object to Processing: The right to object to our processing of your personal data in certain circumstances.

  • The Right to Data Portability: The right to request that we transfer the data we have collected to another organization, or directly to you.

To exercise any of these rights, please contact us at the email address provided in Section 1. We will respond to your request within one month.

 

8. Changes to This Privacy Policy

 

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on this page and updating the "Last Updated" date below.

Last Updated: October 2025

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