1. Who We Are

Business name: Smiths Group, LLC

Websites: RateMyCFIs.com

Email: contact@ratemycfis.com

Mailing address: 4539 N 22nd St, Ste R, Phoenix, AZ 85016

Telephone: 602-888-3014

2. Scope of This Privacy Policy

This Privacy Policy applies to information processed through the Site.

It does not govern the independent privacy practices of:

• Flight instructors;
• Flight schools;
• Designated Pilot Examiners;
• Check Airmen;
• Advertisers;
• Government agencies;
• Linked websites; or
• Other third parties.

The appearance of a person or organization on the Site does not mean that person or organization is affiliated with Smiths Group.

3. Categories of Information We Collect

We may collect information you provide directly, information generated through your use of the Site, information obtained from public records, and information received from third parties.

4. Information We Ask Users Not to Submit

Do not submit unnecessary sensitive information through public reviews, comments, reports, or profile fields.

In particular, do not publish or submit another person's:

• Home address, personal telephone number, or personal email address;
• Certificate number or government identifier;
• Financial information, password, or login credentials;
• Medical information;
• Student or confidential training records; or
• Other sensitive personal information.

This restriction does not apply when information is specifically requested through an appropriate private process. We may redact or remove prohibited information.

5. How We Use Information

We may use information to:

• Create, maintain, authenticate, and secure accounts;
• Operate RateMyCFI and RateMyDPE;
• Publish reviews, ratings, reports, replies, and profile information;
• Calculate ratings, pass rates, fee statistics, and other aggregated information;
• Create, maintain, correct, merge, and mark profiles inactive;
• Process profile creation and claim requests;
• Review certificate images and verify profile claims;
• Operate votes, reports, confidence labels, and moderation systems;
• Detect fraudulent reviews, votes, reports, claims, accounts, brigading, and coordinated manipulation;
• Resolve disputes, corrections, support requests, and privacy requests;
• Send transactional and security-related communications;
• Protect Site infrastructure and investigate unlawful conduct;
• Enforce our Terms and Conditions and protect legal rights;
• Comply with legal obligations and valid legal process;
• Improve Site performance, accessibility, usability, and features;
• Conduct analytics and internal reporting;
• Display, measure, and improve advertising;
• Provide personalized or contextual advertising where permitted;
• Promote the Site and public User Content as authorized by our Terms and Conditions;
• Facilitate a merger, financing, acquisition, sale, or reorganization; and
• Carry out other purposes disclosed when information is collected.

6. Public Information and Visibility

The Site is a public directory and review platform. Publicly displayed information may include display names, reviews, ratings, written comments, training details, checkride outcomes, examiner fees and durations, profile-owner replies, profile photographs, biographies, credentials, locations, business contact information, confidence labels, aggregated ratings, pass rates, median fees, sample sizes, and other professional or community information.

Public information may be viewed by anyone, indexed by search engines, copied, screen-captured, reposted, quoted, archived, shared through social media, or retained by third parties outside our control.

We cannot guarantee that information will disappear from search engines, third-party archives, screenshots, or copies after it is deleted or changed on the Site.

7. Pseudonymous Reviews and Reviewer Identification

A user may select a display name different from the user's legal name. Reviews may therefore appear pseudonymous to readers, but they are not necessarily anonymous to Smiths Group.

Internally, a submission may be associated with account email, account identifier, login information, IP address, timestamps, security records, device or network signals, moderation history, and related communications.

We do not publicly disclose internal reviewer information merely because a profile subject disagrees with a review. We may preserve or disclose relevant information when reasonably necessary to comply with legal process, investigate fraud or threats, enforce our Terms, protect rights or safety, establish or defend legal claims, or obtain legal advice.

We do not guarantee that we will be legally permitted to notify a user before making a disclosure.

8. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, web beacons, tags, local storage, session storage, software development kits, advertising identifiers, IP addresses, and similar technologies.

These technologies may be used to keep users signed in, remember settings, operate features, maintain security, prevent fraud, measure traffic, diagnose errors, understand activity, store consent choices, limit repeated advertisements, measure advertising, and select contextual or personalized advertisements where permitted.

Some cookies are necessary for the Site to function. Others may be optional and subject to your choices or consent where required by law. Blocking necessary cookies may prevent certain features from functioning.

9. Advertising and Google Services

We may use Google AdSense, Google Ads, Google Ad Manager, Google Analytics, or other Google advertising and measurement products.

Google and other advertising vendors may use cookies, web beacons, IP addresses, device identifiers, browser information, approximate location, prior visits to this Site or other websites and apps, advertising interactions, and similar information to serve, personalize, limit, measure, and report on advertisements.

Advertisements may be contextual, personalized, or selected using a combination of these methods. Even when personalized advertising is disabled, providers may continue using cookies or similar technologies for frequency capping, fraud prevention, security, aggregated reporting, measurement, and contextual advertising.

We will not intentionally provide Google with passwords, certificate images, or information that directly identifies a user for advertising personalization.

Where required by law, we will request consent before enabling nonessential advertising cookies or personalized advertising. Opting out of personalized advertising does not necessarily prevent all advertising.

10. Analytics and Performance Monitoring

We may use analytics and performance tools to understand Site use and improve reliability. These tools may collect page visits, interaction events, referring pages, device and browser information, approximate location, IP address, session information, performance data, error messages, and diagnostics.

We use Vercel Analytics to count page views and measure performance. It sets no cookies and builds no profile of you: visits are counted using a value derived from the incoming request that is discarded daily, so it cannot follow you between sites or between days.

We may use error-monitoring services such as Sentry and configure them to reduce unnecessary personal-information collection where reasonably possible. We may also use Google Analytics or similar services in the future.

11. How We Disclose Information

12. Sale, Sharing, and Targeted Advertising

We do not sell personal information in the ordinary sense of exchanging personal information directly for money.

However, advertising cookies, pixels, and identifiers may be treated as a sale, sharing for cross-context behavioral advertising, or processing for targeted advertising under some state laws.

Where applicable, we may provide a "Do Not Sell or Share My Personal Information" link, targeted-advertising opt-out, cookie-consent interface, recognition of supported browser-based opt-out signals, or other legally required controls.

We do not knowingly sell or share the personal information of users under 16 without legally required authorization.

13. Sensitive Personal Information

The Site may process limited sensitive information for verification, security, legal, or safety purposes, including privately submitted certificate images, account credentials, safety-request information, identity-verification details, and information included in legal or harassment complaints.

We do not use certificate images for advertising, marketing, public profiling, public display, ad personalization, or training unrelated artificial-intelligence models.

14. Automated Processing and Integrity Systems

We may use automated rules, risk signals, and algorithms to compare profile requests against public records, detect duplicate profiles, spam, coordinated reviews or voting, suspicious login activity, fraud, and abuse; apply confidence labels; exclude content from aggregate ratings; prioritize moderation; and enforce rate limits.

These systems may use account history, email-verification status, IP address, device or network signals, submission timing, voting patterns, similarity between submissions, public-record matches, reports, and moderator decisions. We may also conduct manual review.

15. Data Retention

We retain information for periods reasonably necessary to operate the Site, maintain accounts and public content, process claims, prevent fraud, maintain security, resolve disputes, enforce agreements, maintain audit trails, comply with law, and establish or defend legal claims.

16. Account Deletion

Users may delete their accounts using available account tools or by contacting us. Before deleting an account, users should separately delete reviews or checkride reports they do not want retained.

When you delete your account:

• Your email address, password hash, account display name, profile photograph, and biography are deleted or disassociated from the active account;
• Published reviews and checkride reports may be retained but permanently disassociated from your account;
• Your display name may be removed from retained submissions;
• Votes and reports may be deleted;
• Pending claims may be canceled;
• Claimed profiles may be released and returned to unclaimed status;
• Claimant-added photographs, biographies, credentials, and contact information may be removed;
• Pending certificate-verification images are deleted; and
• Limited security, fraud-prevention, legal, and transactional records may be retained where necessary and permitted by law.

Deleting an account does not necessarily remove public-record information, profiles created independently, disassociated reviews or reports, third-party archives, search-engine caches, screenshots, independently submitted information, or records we are legally required to retain.

17. Profile Correction and Removal Requests

A person or organization shown on the Site may ask us to correct inaccurate factual profile information, merge a duplicate, address misidentification, mark a profile inactive, review a safety concern, or consider removal where permitted under our Terms and Conditions.

A profile is not automatically deleted because it is unclaimed, contains negative reviews, includes disputed opinions, may affect a business, or is unwanted by the subject.

Correction, merge, misidentification, inactive-profile, and removal requests may be sent to removals@ratemycfis.com from an address we can reply to. Please include a link to the profile and which category applies.

Safety-related requests involving stalking, domestic violence, or similar risks may be handled confidentially and with reduced documentation requirements where appropriate.

18. Your Privacy Rights

Depending on where you live and subject to legal exceptions, you may have rights to:

• Know whether we process your personal information;
• Access, obtain a copy of, correct, or delete certain information;
• Restrict or object to certain processing;
• Withdraw consent where processing is based on consent;
• Request portability;
• Opt out of targeted advertising, sale, or sharing;
• Limit certain uses of sensitive information;
• Opt out of certain profiling or automated decisions;
• Appeal a denied request; and
• Not receive unlawful discriminatory treatment for exercising privacy rights.

These rights are not absolute. We may retain information where permitted or required to exercise free-speech rights, preserve lawful public content, provide services, detect security incidents, prevent fraud, comply with law, establish or defend legal claims, or protect users and the public.

19. California Privacy Rights

California residents may have rights under the California Consumer Privacy Act, as amended, subject to applicable thresholds and exceptions. These may include rights to know, access, correct, delete, opt out of sale or sharing, limit certain uses of sensitive information, use an authorized agent, and receive equal service when exercising privacy rights.

If advertising cookies or similar technologies constitute sharing for cross-context behavioral advertising, California residents may opt out through the mechanism we make available when that activity is enabled and legally applicable.

20. Other U.S. State Privacy Rights

Residents of other U.S. states may have similar rights concerning access, correction, deletion, portability, targeted advertising, sale, profiling, sensitive-data processing, and appeals.

Where required, we will recognize legally valid opt-out preference signals, such as Global Privacy Control, for the browser or device from which the signal is sent.

21. European Economic Area, United Kingdom, and Similar Jurisdictions

The Site primarily concerns United States flight training and is operated from the United States.

If the GDPR, UK GDPR, or a similar law applies, we may process personal information based on:

• Performance of a contract, including operating accounts and requested Site features;
• Our legitimate interests in operating a public professional directory, publishing genuine experiences, moderating content, preventing fraud, maintaining security, correcting information, protecting legal rights, improving the Site, and supporting advertising-funded operations;
• Your consent for nonessential cookies, personalized advertising, optional information, and certain communications;
• Compliance with legal obligations;
• Establishing, exercising, or defending legal claims; or
• Protecting vital interests in an emergency.

Where applicable, you may complain to your local data-protection authority.

22. How to Exercise Privacy Rights

To submit a privacy request, email contact@ratemycfis.com with the subject line Privacy Request.

Please describe the right you wish to exercise, the account or profile involved, the email address associated with your account if any, your state or country of residence, and information reasonably necessary to locate relevant records.

We may verify your identity using access to an account email, information associated with the account, information already maintained by us, a signed declaration, or another reasonable method.

If we deny a request and applicable law grants an appeal right, you may appeal by replying to our decision with the subject line Privacy Appeal.

23. Advertising and Cookie Choices

Depending on your location and enabled services, you may manage advertising and cookies through a cookie-consent banner, privacy settings page, "Do Not Sell or Share My Personal Information" link, targeted-advertising opt-out, Google advertising settings, industry opt-out tools, Global Privacy Control, browser controls, device settings, or other provider mechanisms.

Clearing cookies, using another browser, or changing devices may require you to renew your choices. Some opt-outs apply only to the browser or device where the choice is made.

24. Email Communications

We may send transactional or service-related emails concerning email verification, password resets, account security, reviews, reports, moderation, profile claims, disputes, privacy requests, policy changes, legal notices, and other Site operations.

You generally cannot opt out of communications necessary to operate or secure an active account. Optional marketing emails will include an unsubscribe mechanism where required by law.

25. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. These may include password hashing, access controls, private object storage, separation of public and private files, authentication requirements, sensitive-access logging, metadata removal, transport encryption, restricted administrator privileges, monitoring, backups, vendor controls, and incident-response procedures.

No method of transmission, storage, or security is completely secure. We cannot guarantee absolute security or that unauthorized access, interception, copying of public information, or vulnerabilities will never occur.

26. Data Breach Notification

If a security incident affects personal information, we will investigate and provide legally required notices to affected individuals, regulators, or others within the time required by applicable law.

27. International Data Transfers

The Site is operated in the United States. Information may be transferred to, stored in, or processed in the United States and other countries where our service providers operate.

Where required, we may use lawful transfer mechanisms such as standard contractual clauses, data-processing agreements, adequacy decisions, contractual safeguards, or other approved mechanisms.

28. Children's Privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13.

Users must be at least 13 to create an account or submit content. A user under the age of legal majority may use the Site only with the permission and supervision of a parent or legal guardian, as described in our Terms and Conditions.

We do not knowingly use information from users known to be under 13 for personalized advertising. If we learn that we collected personal information from a child under 13 without legally sufficient authorization, we will take reasonable steps to delete it.

A parent or guardian who believes a child under 13 provided personal information may contact contact@ratemycfis.com.

29. Third-Party Links, Embeds, and Services

The Site may link to or integrate third-party websites, social-media platforms, maps, videos, advertising, analytics, aviation databases, government records, tools, and services.

Third parties may collect information directly from you and apply their own privacy policies. We are not responsible for third-party privacy, security, content, or business practices.

30. Do Not Track

Some browsers provide a "Do Not Track" setting. There is no universally accepted standard governing all responses to Do Not Track signals, so the Site may not respond to traditional Do Not Track signals in all circumstances.

Where required by law, we may recognize supported opt-out preference signals, such as Global Privacy Control, for applicable sale, sharing, or targeted-advertising opt-outs.

31. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date.

For material changes, we may provide notice through the Site, email, an account notification, a banner, or another reasonable method. If a change requires consent under applicable law, we will request consent as required.

32. Contact Us

Questions, privacy requests, and complaints may be directed to:

For faster processing, use the subject line Privacy Request.

Some matters reach us faster at a dedicated address:

• Privacy questions, requests, and complaints: contact@ratemycfis.com
• Profile corrections, misidentification, and removal requests: removals@ratemycfis.com
• Copyright and DMCA notices, including counter-notifications: digitalrights@smithsgroup.net (ATTN: Digital Rights Office)