Alfa-Comm · Privacy
Privacy Policy
Last updated: October 2026
1. Who we are
ICAO English is an aviation English practice application operated by Uri Oram, a VAT-registered sole proprietor (עוסק מורשה) trading as Alfa-Comm, of 15 Shoham Street, Mevaseret Zion, Israel, and a certified flight instructor and ICAO rater. For the purposes of the Protection of Privacy Law, 5741-1981, Uri Oram is the owner of the database in which your personal information is held. This policy explains what personal data the app collects, how it is used, where it is processed, and the rights you have over it.
2. Data we collect
- Account information: your email address, your chosen password, and your name if you choose to provide one.
- Audio recordings and transcripts: voice recordings you submit for grading in the Picture Description and ATC Readback modules, and the automatic text transcript generated from each recording.
- Usage and progress data: practice activity such as completed scenarios, scores, attempts and graded results.
- Payment information: payments are handled by PayPlus — the app does not receive or store your card details.
- Reviews you submit: if you choose to leave a review, the name, role, rating and review text you enter. This is the only information in this app that is published for anyone to see — see Section 7.
3. Purpose of processing your recordings
Recordings you submit in the Picture Description and ATC Readback modules are transcribed and graded automatically for the sole purpose of scoring your spoken English against the ICAO Language Proficiency Rating scale and giving you practice feedback. Recordings are linked to your account, are used only for this purpose, and are not shared publicly or used to train any third party's models beyond the processing described in Section 4.
4. Cross-border transfer of your recordings
Transcription and grading are performed for us by Base44, Inc., the software platform this app is built on. This means your recording, its transcript and its score are transferred from Israel to Base44 and, through Base44, to the AI providers it uses to perform transcription and language assessment — currently OpenAI and Anthropic — together with the infrastructure providers Base44 uses to store and process that data (including MongoDB for data storage and Supabase for media hosting). Based on Base44's own published sub-processor list, these providers process data in the United States.
This is a transfer of personal information outside Israel within the meaning of the Protection of Privacy Regulations (Transfer of Data to Databases Outside of Israel), 5761-2001. We only use processors who are contractually bound, under Base44's Data Processing Addendum, to use the data solely to provide the transcription and grading service to us and to apply appropriate security measures.
5. How long we keep your data
We keep your account data, recordings, transcripts and graded results for as long as your account remains open, so that you can review your practice history. We do not currently apply an automatic deletion period to older recordings. You can permanently delete your account and everything associated with it at any time — see Section 8.
6. Payments
All payments are processed securely by PayPlus (Israeli payment clearing). Alfa-Comm never sees, receives or stores your card details. Payment records are retained by PayPlus under its own privacy policy.
7. Reviews
Leaving a review is entirely optional. If you submit one, the name and role you enter are published on the Reviews page next to your review once it is approved — so enter a name you are content to have shown publicly; a first name or initials is fine. Nothing is published before approval, and we may decline to publish a review.
A published review stays on the page until you ask us to remove it. To have yours taken down, or to correct it, email contact@alfa-comm.com. Where a reviewer was given free access to the app in exchange for honest feedback, that is noted alongside their review.
8. Children
The service is not intended for children under 16, and we do not knowingly collect personal data from children under 16.
9. Your rights, and account deletion
Under the Protection of Privacy Law, 5741-1981, you have the right to access the personal information we hold about you, to request that it be corrected, and to request its deletion. You can delete your account and all associated data — including your progress records, graded attempts and recordings — at any time from your account settings page; this is permanent and cannot be undone. For any other access or correction request, or if you believe your privacy rights have not been respected, you may also contact the Israeli Privacy Protection Authority.
10. Contact us
For any privacy question, or a data access, correction or deletion request, reach out via the contact page or by emailing contact@alfa-comm.com.
