Privacy Policy

Version 1.0 · Effective 2026-08-15 · Operator Cockpit, a product of SKIPPER CRO LLC (Delaware, USA)

PRIVACY POLICY

Operator Cockpit

Last updated: August 15, 2026
Version: 1.0

THIS POLICY EXPLAINS WHAT PERSONAL DATA OPERATOR COCKPIT COLLECTS, WHY WE COLLECT IT, WHO WE SHARE IT WITH, HOW LONG WE KEEP IT, AND THE RIGHTS YOU HAVE OVER IT. IT COVERS THE OPERATOR COCKPIT WEBSITE, WEB APPLICATION, MOBILE APPLICATIONS FOR ANDROID AND iOS, AND OUR APPLICATION PROGRAMMING INTERFACES (TOGETHER, THE "SERVICES").

SECTION 3 IS THE MOST IMPORTANT SECTION TO READ FIRST. IT EXPLAINS THAT WE HOLD TWO DIFFERENT KINDS OF PERSONAL DATA UNDER TWO DIFFERENT ROLES, AND THAT WHICH ROLE APPLIES DETERMINES WHO YOU SHOULD CONTACT ABOUT YOUR DATA.


1. WHO WE ARE

1.1 Controller identity. The Services are operated by SKIPPER CRO LLC, a limited liability company organized under the laws of the State of Delaware, United States of America, Employer Identification Number (EIN) 98-1861436, with its registered address at 8 The Green, Ste B, Dover, DE 19901, United States ("Operator Cockpit", "the Company", "we", "us", "our"). Operator Cockpit is a trading and product name of the Company.

1.2 How to contact us about privacy. Write to privacy@operatorcockpit.com. This is the address to use for any question about this policy, any request to exercise a right described in Section 9, and any complaint about how we have handled personal data. We aim to acknowledge a rights request within seven (7) days and to complete it within thirty (30) days, or to explain in that time why we need longer, in accordance with applicable law.

1.3 Other contact addresses. For general support, support@operatorcockpit.com. For formal legal notices, legal@operatorcockpit.com. Our postal address for formal notices is the registered address in Section 1.1.

1.4 EU and UK representative. As of the date of this policy the Company has not appointed a representative under Article 27 of the EU General Data Protection Regulation or its UK equivalent. Where we become required to appoint one, we will name that representative in this policy and give notice of the appointment. In the meantime, requests and complaints from individuals in the European Economic Area or the United Kingdom should be sent to privacy@operatorcockpit.com and are handled under Sections 9 and 10.


2. WHO THIS POLICY IS FOR

2.1 Operators. Operator Cockpit is a business-to-business platform for tour operators, charter companies, activity providers, rental businesses, and similar travel and leisure supply businesses ("Operators"), and for the individual owners, staff, and crew who use an Operator's account ("Account Users"). If you registered for or use an Operator Cockpit account, this policy describes how we handle your data.

2.2 Guests. If you are a traveler, customer, or client of an Operator ("Guest"), and you booked a tour, charter, activity, rental, or other service from that Operator, we may hold data about you because that Operator uses our software to run its business. In that situation the Operator, not the Company, decides what data is collected about you and why. Section 3.2 explains what this means for you and who to contact.

2.3 Visitors. This policy also covers visitors to our public website and to public pages generated through the Services, such as an Operator's public listing or a payment page.

2.4 Children. The Services are not directed to children. They are business tools intended for use by people aged eighteen (18) or over acting in a professional capacity, and we do not knowingly collect personal data from a child under the age of sixteen (16). If you believe a child has provided us with personal data, write to privacy@operatorcockpit.com and we will delete it.


3. THE TWO ROLES WE ACT IN

3.1 Where we are the controller. We are the data controller for personal data about Operators and Account Users: your account and identity data, your billing and subscription data, your use of the Services, your communications with our support team, and the security and audit records we keep about your account. For this data we decide the purposes and means of processing, and the rest of this policy describes what we do and why. Direct any request about this data to privacy@operatorcockpit.com.

3.2 Where we are the processor. We are a data processor, acting on the Operator's documented instructions, for personal data about Guests, and for personal data about an Operator's own staff and crew that the Operator enters into the Services. The Operator decides what Guest data to collect, what to do with it, and how long to keep it; we store and process it on the Operator's behalf so that the Operator can run its business. We do not sell Guest data, do not use it to market to Guests on our own account, and do not use it for our own independent purposes.

If you are a Guest and you want to access, correct, or delete data an Operator holds about you, contact that Operator directly, because they control it and we are not permitted to act on it without their instruction. If you do not know which Operator holds your data, or cannot reach them, write to privacy@operatorcockpit.com and we will help you identify the right party and, where we are permitted and able, pass your request on.

3.3 Why the distinction matters. The two roles carry different legal duties and different points of contact. It is not a way of avoiding responsibility: as processor we remain bound by a data processing agreement with the Operator, by the security obligations in Section 8, and by the sub-processor and transfer rules in Sections 6 and 7.


4. WHAT WE COLLECT, AND WHY

4.1 Account and identity data. When you register, we collect your name, email address, and password, which is stored only as a salted one-way hash and never in a form we can read. We may also collect a telephone number, your business name and business address, your role within the business, and a profile photograph if you choose to upload one. We use this to create and secure your account, to identify you when you sign in, to communicate with you about your account, and to provide support. Legal basis: performance of our contract with you, and our legitimate interest in operating and securing the Services.

4.2 Business and operational content. When you use the Services you enter content about your business: your listings and products, availability calendars and schedules, prices, bookings, invoices, documents, messages, and the staff and crew records you choose to create. Where this content contains personal data about Guests or about your staff, we hold it as processor under Section 3.2. We use it to provide the features you asked for. Legal basis: performance of our contract with you, and, for the personal data within it, the Operator's own basis as controller.

4.3 Billing and subscription data. If you buy a paid subscription we collect and hold your subscription tier, billing period, invoice history, usage against your plan allowances, billing country, and any tax identification number you provide. We do not collect or store your full payment card number in any circumstance.

If you subscribe on the web, our payment processor Stripe, Inc. collects and holds your card details directly, and we receive from Stripe only a token, the card brand, and the last four digits, so that we can show you which card is on file.

If you subscribe through the Google Play Store, Google takes the payment and we never see your payment details at all. Google tells us that a purchase exists, which plan it corresponds to, whether it is currently valid, and when the current period ends. To link that purchase to your account we send Google an obfuscated identifier derived from your account identifier at the moment of purchase, and Google returns it to us when it tells us about the purchase; we do not send Google your name, email address, or any other identifying detail, and Google does not send us your Google account identity.

Legal basis: performance of our contract with you, and compliance with our legal obligations regarding tax and financial records.

4.4 Usage and device data. We record how the Services are used: pages and screens opened, features used, requests made to our API, the counts we meter for billing under our Terms, timestamps, approximate location inferred from IP address at the country or city level, IP address, browser or mobile application version, device model, and operating system version. We use this to operate and secure the platform, to detect and investigate abuse and fraud, to bill metered usage accurately, to diagnose faults, and to understand which features are used so that we can improve them. Legal basis: our legitimate interest in operating, securing, and improving the Services, and performance of our contract with you for the metering that determines what you are billed.

4.5 Security and audit records. We keep audit logs of significant actions taken in an account — sign-ins, permission changes, billing changes, data exports, deletions — together with the IP address and device the action came from. These records are how we can tell you what happened if something goes wrong, and how we detect account takeover and abuse. Legal basis: our legitimate interest in security and fraud prevention, and compliance with our legal obligations.

4.6 Support communications. When you contact support we keep your messages, our replies, and any attachment you send. We use these to answer you, to keep a record of what was agreed, and to improve our support. Legal basis: performance of our contract with you and our legitimate interest in maintaining a record of support.

4.7 Marketing communications. If you opt in, we send occasional product and feature emails. You can withdraw consent at any time using the unsubscribe link in any such email or in your notification settings. Withdrawing consent does not stop account and billing notices — such as a receipt, a renewal reminder, a failed payment notice, or a usage-allowance warning — because those are necessary to the contract and are not marketing. Legal basis: your consent for marketing; contract for account and billing notices.


5. THE MOBILE APPLICATION SPECIFICALLY

This Section describes what the Android and iOS applications do on your device. It is written to correspond to the Data safety disclosure we publish on the Google Play Store; if you find a discrepancy between the two, write to privacy@operatorcockpit.com and we will correct it.

5.1 Camera. The application can use your device camera to scan a booking check-in code and to photograph a listing or a document you want to attach. The camera is opened only when you tap a control that needs it. Images are uploaded to your account only when you choose to attach them. We do not access the camera in the background and we do not capture images without you initiating it.

5.2 Photo library. If you choose to upload an existing image, the application asks for access to the photo you select. We receive only the images you pick, not your library.

5.3 Location. If you use a feature that sets a pickup point, meeting point, or similar location on a listing or a booking, the application can ask permission to read your device location so that it can pre-fill that point for you. Location is read only while the application is open and only when you have used such a feature, is never collected in the background, and is not used for advertising, profiling, or tracking. You can decline the permission and enter the location manually instead; no feature becomes unavailable to you if you decline.

5.4 Notifications. If you allow notifications, we register a push notification token for your device with Google Firebase Cloud Messaging on Android and with the Apple Push Notification service on iOS, and we store it against your account so that we can deliver a notification to that device. The token identifies the device installation, not you personally. We use notifications for account, booking, message, and billing events. You can revoke notification permission in your device settings at any time; the token is then no longer usable and we delete it when we next find it invalid.

5.5 Credentials on the device. Your session credentials are stored using the operating system's own secure credential storage — the Android Keystore-backed store and the iOS Keychain — and not in ordinary application storage.

5.6 Advertising and tracking. The mobile application contains no advertising software development kit, no advertising identifier collection, no cross-application tracking, and no third-party analytics that profile you across other applications or websites. We do not sell or share personal data for cross-context behavioural advertising as those terms are defined under United States state privacy laws.

5.7 In-app purchases. If you buy a subscription inside the Android application, the purchase is made through Google Play's billing system as described in Section 4.3 and in Section 7A of our Terms and Conditions. The application does not collect your payment details.


6. WHO WE SHARE DATA WITH

6.1 We do not sell personal data. We have not sold personal data in the preceding twelve months and do not do so. We do not share personal data with third parties for their own independent marketing purposes.

6.2 Service providers (sub-processors). We use a small number of providers to run the Services. Each is bound by contract to process personal data only on our instructions and to maintain appropriate security. As of the date of this policy they are:

  - Railway Corp. — application and database hosting.
  - Supabase, Inc. — database and authentication infrastructure.
  - Stripe, Inc. — payment processing for web subscriptions, and payment facilitation for Operators who connect their own Stripe account.
  - Google LLC — Google Play billing for in-app purchases on Android; Firebase Cloud Messaging for Android push notifications; Google Maps geocoding where an address is looked up.
  - Apple Inc. — Apple Push Notification service for iOS notifications, and App Store billing where in-app purchase is offered on iOS.
  - Amazon Web Services, Inc. — object storage for files and images.
  - Resend, Inc. — transactional email delivery.
  - Anthropic PBC — the assistive features of the Services, where you choose to use them, and then only for the content of the specific request you make.

We keep this list current. Where we add or replace a provider that processes personal data, we update this policy and, where we act as processor for an Operator, we give that Operator the notice our data processing agreement requires.

6.3 Marketplaces and channels you connect. If you connect a sales channel, marketplace, or partner platform to your account, we send that platform the data necessary for the connection to work — typically your listings, availability, prices, and the booking and Guest details required to fulfil a booking. You choose which platforms to connect and can disconnect them at any time. Once data reaches a platform you connected, that platform handles it under its own privacy policy and we have no control over it.

6.4 Legal and protective disclosure. We may disclose personal data where we are required to by law, by a court, or by a competent authority; where it is necessary to establish, exercise, or defend a legal claim; or where it is necessary to prevent or investigate fraud, abuse, a security incident, or a threat to the safety of any person. Where we are legally permitted to tell you about such a request before responding to it, we will.

6.5 Business transfer. If the Company is involved in a merger, acquisition, financing, or sale of assets, personal data may be transferred as part of that transaction. We will give notice before your data becomes subject to a different privacy policy, and the recipient will remain bound by this policy until it does.


7. INTERNATIONAL TRANSFERS

7.1 Where data is processed. The Company is established in the United States and our infrastructure and providers process data in the United States and in the European Union. If you are located in the European Economic Area, the United Kingdom, or Switzerland, your personal data is transferred to and processed in the United States.

7.2 Safeguards. We rely on the European Commission's Standard Contractual Clauses, and the United Kingdom's International Data Transfer Addendum where applicable, in our contracts with providers that process personal data outside the EEA or the UK, together with the technical measures described in Section 8. You may request a copy of the relevant safeguard by writing to privacy@operatorcockpit.com; we may redact commercial terms from any copy we provide.


8. HOW WE PROTECT DATA

8.1 Technical measures. All traffic to the Services is encrypted in transit using TLS. Data is encrypted at rest by our hosting and storage providers. Particularly sensitive fields — including Guest contact details, stored credentials for connected platforms, and message bodies — are additionally encrypted at the application layer, so that they are unreadable in a database dump without a separate key that is not stored in the database.

8.2 Access controls. Access to production data is restricted to the small number of people who need it, is authenticated, and is logged. Database-level access rules are applied so that one Operator's data cannot be read by another Operator even in the event of an application-layer fault.

8.3 Passwords. Passwords are stored only as salted one-way hashes. Neither we nor our support staff can read your password, and we will never ask you for it.

8.4 Honest limits. No system is perfectly secure. We cannot guarantee that unauthorised access, loss, or disclosure will never happen. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, you, without undue delay, and we will tell you what we know and what we are doing about it.


9. YOUR RIGHTS

9.1 Rights available to you. Subject to the conditions and exceptions in applicable law, you have the right to: obtain confirmation of whether we process your personal data and a copy of it; have inaccurate data corrected; have data erased; restrict processing in certain circumstances; object to processing carried out on the basis of our legitimate interests, including a right to object at any time to direct marketing; receive the data you provided to us in a structured, commonly used, machine-readable format and have it transmitted to another controller where technically feasible; and withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.

9.2 Rights under United States state laws. If you are a resident of California or of another United States state with a comprehensive privacy law, you also have the rights that law gives you, which typically include a right to know, a right to delete, a right to correct, a right to opt out of sale or sharing for cross-context behavioural advertising, and a right not to be discriminated against for exercising a right. As stated in Sections 5.6 and 6.1 we do not sell or share personal data for cross-context behavioural advertising, so there is nothing to opt out of; if that ever changes we will publish an opt-out mechanism before it does. We do not use personal data to make decisions that produce legal or similarly significant effects about you by automated means alone.

9.3 How to exercise a right. Write to privacy@operatorcockpit.com from the email address on your account, or use the controls in the Services where they are available. We will verify your identity before acting, because acting on an unverified request is itself a data breach. If you are a Guest, Section 3.2 explains why your request usually goes to the Operator rather than to us.

9.4 Complaints. If you are unhappy with how we have handled your personal data, tell us first at privacy@operatorcockpit.com so that we have a chance to fix it. You also have the right to complain to a data protection supervisory authority, in the EEA in the member state of your habitual residence, place of work, or the place of the alleged infringement; in the United Kingdom, to the Information Commissioner's Office. You are not required to contact us first.


10. DELETING YOUR ACCOUNT AND YOUR DATA

10.1 How to delete your account. You can delete your account yourself, without contacting us and without explaining why:

  - On the web, sign in and go to https://operatorcockpit.com/account/settings, then use "Delete account".
  - In the mobile application, open Settings, then Account, then "Delete account".
  - If you cannot sign in, write to privacy@operatorcockpit.com from the email address on the account and we will verify you and delete it.

10.2 What deletion does. Deleting your account ends your access, removes your profile and identity data, and begins deletion of the content in your account. Cancelling a paid subscription is a separate action from deleting an account, and deleting an account does not by itself cancel a subscription bought through an app store: if you subscribed through the Google Play Store, cancel the subscription in the Play Store as well, as Section 7A.6 of our Terms explains, so that Google stops charging you.

10.3 What survives deletion, and why. We retain, after deletion:

  - Invoices, receipts, and the underlying transaction records, for as long as tax and accounting law requires us to keep them, which is generally seven (7) years.
  - Security and audit records of the account, for up to twelve (12) months, so that we can investigate fraud, abuse, or a security incident that is discovered after the account is gone.
  - Records necessary to establish, exercise, or defend a legal claim, for as long as that claim can be brought.
  - A minimal suppression record — an irreversible hash of the deleted email address — where you have asked not to be contacted again, so that we can honour that request without keeping your address in readable form.

Anything not in this list is deleted within ninety (90) days of your request, including from routine backups as those backups age out on their normal cycle. We also retain aggregated or de-identified statistics that cannot be linked back to you or to your account.

10.4 Guest data on deletion. Where we hold Guest data as processor for you, deleting your account deletes that data on the same schedule. If you are subject to your own retention obligations for that data, export it before you delete your account.


11. HOW LONG WE KEEP DATA WHILE YOUR ACCOUNT IS OPEN

11.1 Account and content data is kept for as long as your account is open, because that is what the account is for. 11.2 Usage and metering records are kept for twenty-four (24) months, after which they are aggregated. 11.3 Security and audit records are kept for twelve (12) months. 11.4 Support conversations are kept for twenty-four (24) months after the case is closed. 11.5 Financial records are kept for the period tax and accounting law requires, generally seven (7) years. 11.6 Push notification tokens are deleted when the device unregisters or the token is reported invalid.


12. COOKIES AND SIMILAR TECHNOLOGIES

12.1 What we use. Our website and web application use cookies and equivalent browser storage that are strictly necessary to sign you in, keep your session, remember your preferences, and protect against cross-site request forgery. We use a limited amount of first-party analytics to understand how the site is used. We do not use advertising cookies and we do not permit third-party advertising trackers on our own properties.

12.2 The mobile application. The mobile application does not use cookies for its own function; it stores its session credential in secure device storage as described in Section 5.5. Where a screen in the application opens a web page of ours, that page follows this Section.

12.3 Managing cookies. Your browser lets you block or delete cookies. Blocking strictly necessary cookies will stop you being able to sign in. Our Cookie Policy, published alongside this policy, gives the detail.


13. CHANGES TO THIS POLICY

13.1 We may update this policy to reflect a change in the Services, in our providers, or in the law. When we do, we change the "Last updated" date at the top and raise the version number. Where a change materially affects how we use personal data about you, we give notice in the Services or by email at least thirty (30) days before it takes effect, so that you have time to object, to exercise a right, or to delete your account before it applies.

13.2 We keep prior versions and will provide one on request to privacy@operatorcockpit.com.


14. CONTACT

Privacy and data protection: privacy@operatorcockpit.com
Support: support@operatorcockpit.com
Legal notices: legal@operatorcockpit.com

SKIPPER CRO LLC
8 The Green, Ste B
Dover, DE 19901
United States


END OF PRIVACY POLICY