Savvy and your Data…

[exM20K]

If you choose not to share data, be sure to keep the data card out of the plane.  There really is nothing to prevent the technician doing a pre-buy from uploading those data on his or her own. or just populating and examining spreadsheets.

 

-dan

[wombat]

1 hour ago, Shadrach said:

1) What is Savvy’s policy and are they adhering to it.

I think this is really the most important part.   They include engine monitor data in their definition of Personally Identifiable Information,  which they say they can use to provide services to their clients.   

So.....   To me this is poorly defined but I'd say that if you were a prebuy client for a plane that I had uploaded data for, it is within their policy to provide my engine monitor data to you.     This is not my favorite policy and while I'm not about to go deleting my engine monitor data, I am probably going to (very slightly) more aggressively look for alternatives.

Also, they can use the data you uploaded to help prevent fraud.  So if someone said in an ad that their engine was 200 hours SMOH and always ran cool but the engine monitor data shows regular trips to CHT500, reporting on that would also be within their policy.

 

https://apps.savvyaviation.com/legal 

From that page it says:

What information does Savvy collect and store online?
Personally identifiable information Savvy collects can include credit card information, contact information (such as name, mailing address, email address and telephone numbers), insurance information, aircraft information, aircraft logbook data, engine monitor data, oil analysis data, communications with Savvy on the website ticket system and other information necessary to service the User. Savvy reserves the right to retain the User's information even if the User ceases using the Online Services. Users can review certain personally identifiable information on Savvy's website, and can request that Savvy modify certain personally identifiable information by contacting Savvy through email at privacy@savvymx.com.

Savvy does not collect information from anyone under 13 years of age. Savvy's website and services are directed at persons older than 13 years of age.

How does Savvy use the information it collects?
Except as stated elsewhere in this Privacy Policy, personally identifiable User information is only used for the purpose of providing or improving Savvy’s services to its clients or other Users. Savvy will not sell, trade, or otherwise transfer to outside parties the User's personally identifiable information. This does not include trusted third parties who assist us in operating Savvy's website, conducting Savvy's business, or servicing you, so long as those parties agree to keep this information confidential. Certain information provided by Users is shared with the aircraft service centers that do examinations, inspections and/or maintenance of the User's aircraft. Information provided by service centers might be shared with Savvy's clients. Nevertheless, Savvy may disclose any User information to third parties if Savvy believes the disclosure to (i) be necessary to comply with any law, regulation, subpoena, or court order, or (ii) help prevent fraud or to enforce or protect the rights and properties of Savvy.

Savvy may, from time to time, share User information with third parties, provided that the information is not personally identifiable. The User grants Savvy a worldwide license to use, host, store, reproduce, modify, create derivative works, communicate, publish, and distribute such information. The license continues even if the User stops using Savvy's services.

[Shadrach]

21 minutes ago, wombat said:

I think this is really the most important part.   They include engine monitor data in their definition of Personally Identifiable Information,  which they say they can use to provide services to their clients.   

So.....   To me this is poorly defined but I'd say that if you were a prebuy client for a plane that I had uploaded data for, it is within their policy to provide my engine monitor data to you.     This is not my favorite policy and while I'm not about to go deleting my engine monitor data, I am probably going to (very slightly) more aggressively look for alternatives.

Also, they can use the data you uploaded to help prevent fraud.  So if someone said in an ad that their engine was 200 hours SMOH and always ran cool but the engine monitor data shows regular trips to CHT500, reporting on that would also be within their policy.

 

https://apps.savvyaviation.com/legal 

From that page it says:

What information does Savvy collect and store online?
Personally identifiable information Savvy collects can include credit card information, contact information (such as name, mailing address, email address and telephone numbers), insurance information, aircraft information, aircraft logbook data, engine monitor data, oil analysis data, communications with Savvy on the website ticket system and other information necessary to service the User. Savvy reserves the right to retain the User's information even if the User ceases using the Online Services. Users can review certain personally identifiable information on Savvy's website, and can request that Savvy modify certain personally identifiable information by contacting Savvy through email at privacy@savvymx.com.

Savvy does not collect information from anyone under 13 years of age. Savvy's website and services are directed at persons older than 13 years of age.

How does Savvy use the information it collects?
Except as stated elsewhere in this Privacy Policy, personally identifiable User information is only used for the purpose of providing or improving Savvy’s services to its clients or other Users. Savvy will not sell, trade, or otherwise transfer to outside parties the User's personally identifiable information. This does not include trusted third parties who assist us in operating Savvy's website, conducting Savvy's business, or servicing you, so long as those parties agree to keep this information confidential. Certain information provided by Users is shared with the aircraft service centers that do examinations, inspections and/or maintenance of the User's aircraft. Information provided by service centers might be shared with Savvy's clients. Nevertheless, Savvy may disclose any User information to third parties if Savvy believes the disclosure to (i) be necessary to comply with any law, regulation, subpoena, or court order, or (ii) help prevent fraud or to enforce or protect the rights and properties of Savvy.

Savvy may, from time to time, share User information with third parties, provided that the information is not personally identifiable. The User grants Savvy a worldwide license to use, host, store, reproduce, modify, create derivative works, communicate, publish, and distribute such information. The license continues even if the User stops using Savvy's services.

It reads to me like if you upload engine monitor data to the savvy website, you should expect that the data may be shared with Savvy clients.

[wombat]

10 minutes ago, Shadrach said:

It reads to me like if you upload engine monitor data to the savvy website, you should expect that the data may be shared with Savvy clients.

Yup.  That's how I read it too.

[Schllc]

43 minutes ago, wombat said:

provided that the information is not personally identifiable

Unfortunately words are subject to interpretation, and it is difficult to word everything in a way that no one will misunderstand. Sharing data with a buyer without my consent is absolutely personally identifiable. 
When I created my account, loaded my data and looked at it, it never occurred to me that this would be shared with a prospective buyer without my consent. 
is this my fault for misunderstanding the policy?    
Probably… 
 

Now I know exactly what Savvy can do with my data, and why I posted it on this forum so everyone else understood as well.
It appears most people understood those terms exactly as I did…
This should clear up any ambiguity. 

[wombat]

Savvy says pretty clearly that they consider engine monitor data personally identifiable; that part is not really up for debate.

 

What could be non-identifiable would be something like "The average number of CHT seconds over 420F per day for TSIO-550 engines, for all TSIO-550 engines with data"

IFF (If and only if) they have at least some non-trivial quantity of different TSIO-550 engine data during that time period.

 

It's interesting that @kortopates seems to have had the same expectation that most of the rest of us did, that Savvy would not provide your data or derivative information from your data to other customers.

[kris_adams]

"The User grants Savvy a worldwide license to use, host, store, reproduce, modify, create derivative works, communicate, publish, and distribute such information. The license continues even if the User stops using Savvy's services."  Looks like they whatever they want with your data.

There you go.  I suspected there would be an EULA with something like this called out.

In today's world this needs to be shared very widely.

-K

[wombat]

@kris_adams That section is explicit about applying only to information that is "not personally identifiable" and they clearly call out engine monitor data as personally identifiable. 

With more context, it reads: Savvy may, from time to time, share User information with third parties, provided that the information is not personally identifiable. The User grants Savvy a worldwide license to use, host, store, reproduce, modify, create derivative works, communicate, publish, and distribute such information.

[Jetpilot86]

The other Bravo I looked at before getting mine had an engine which had a stressed first 600 hours with two cylinders being replaced during that time.  It had a JPI model with the downloadable data, the owner, an A&P, feigned ignorance of having the ability to download it, it's the one requiring a cable, nor could/would the prebuy MSC do so.  Needless to say, when a 3rd cylinder showed up with a burned exhaust valve on the borescope during the prebuy at 700 SMOH, I was done with the deal, especially absent that data to review.

As a paying customer of Savvy, I would definitely expect a direct request to share my identified engine data with anyone.  Having said that, I'd also probably be including the data, just like logbooks, as part of my sales pitch to a prospective buyer; so if they subsequently shared it with Savvy again, the point is moot anyway.  

If I was using the free upload service only, I'd have less expectation of privacy because of getting the service "free", and might make the data less identifiable to my specific airframe as a result.  Free is rarely "free", just free to you.  The parallel, is GMail.  They probably make everything other than my name identifiable to advertisers to make money from all the free services they give me.

[kris_adams]

15 hours ago, wombat said:

@kris_adams That section is explicit about applying only to information that is "not personally identifiable" and they clearly call out engine monitor data as personally identifiable. 

Per this thread, they literally shared the "personally identifiable"  information that you point out above with another person...so is the policy being misread or did they violate their own privacy policy...

[redbaron1982]

2 minutes ago, kris_adams said:

Per this thread, they literally shared the "personally identifiable"  information that you point out above with another person...so is the policy being misread or did they violate their own privacy policy...

Actually I think here it says that they can use one user's data (in this case the seller) to provide a better service to another user (in this case the buyer):

Except as stated elsewhere in this Privacy Policy, personally identifiable User information is only used for the purpose of providing or improving Savvy’s services to its clients or other Users. 

[exM20K]

The privacy policy appears to date from more than 10 years ago, and I think it would benefit Savvy to update and clarify it and/or publish some statement on how your data is accessed by third parties and for what purpose.

@kortopates mea culpa is a good start, but it’s not obvious he speaks for the company. I believe there was no intent to abuse the OP, but rather there was a break in communications internally at Savvy.

From some of the good points raised in this thread, I’d be happy if they stated clearly that

• Savvy will use your anonymized data for creation of aggregated fleet, model, or manufacturer benchmarks
• Savvy will process and analyze uploaded data for a plane regardless of who uploads it. (They can’t possibly determine if Joe Smith is the managing member of XYZ Llc, and many technicians will upload data on behalf of their customers.)
• Savvy will share data and/or analysis with third parties only with prior permission of the account holder.
• Savvy pre-buy will not disclose if a plane is enrolled in the data logging.

The existing privacy policy statement appears to be generic language, and perhaps their attorney feels they need this precise language. I believe the bigger risk to the company is the reputational risk of being indiscreet with private data than is the risk of some complaint covered by the current policy.

I’m a big fan of Savvy and happily pay for the analysis.  @kortopates must be growing weary of my long list of issues, but I think we have both learned a lot working through them together. I would like this company to prosper, and I believe a clear statement of how they protect YOUR data will help ensure future success.

-dan

[wombat]

1 hour ago, kris_adams said:

Per this thread, they literally shared the "personally identifiable"  information that you point out above with another person...so is the policy being misread or did they violate their own privacy policy...

@redbaron1982 is right.   And I pretty much agree with @exM20K's proposed policy statement.

 

 There are two types of 'sharing' or 'using' going on here.    Their policy says that they can use PII (Personally Identifiable Information)  "for the purpose of providing or improving Savvy’s services to its clients or other Users."    This is what happened that caused this whole thread to start.   

They also say "Savvy will not sell, trade, or otherwise transfer to outside parties the User's personally identifiable information." but they do note that they can "share User information with third parties, provided that the information is not personally identifiable"         They can't provide your engine monitor data to a 3rd party unless that third party is a user or client.  But if they make it non personally identifiable, they can.

[Schllc]

40 minutes ago, wombat said:

@redbaron1982 is right.   And I pretty much agree with @exM20K's proposed policy statement.

 

 There are two types of 'sharing' or 'using' going on here.    Their policy says that they can use PII (Personally Identifiable Information)  "for the purpose of providing or improving Savvy’s services to its clients or other Users."    This is what happened that caused this whole thread to start.   

They also say "Savvy will not sell, trade, or otherwise transfer to outside parties the User's personally identifiable information." but they do note that they can "share User information with third parties, provided that the information is not personally identifiable"         They can't provide your engine monitor data to a 3rd party unless that third party is a user or client.  But if they make it non personally identifiable, they can.

I don't believe they can make it non personally identifiable, I mean the buyer knows the seller, and Savvy cannot keep anything confidential at that point.

[dkkim73]

19 minutes ago, Schllc said:

I don't believe they can make it non personally identifiable, I mean the buyer knows the seller, and Savvy cannot keep anything confidential at that point.

I wonder if the deeper problem is the conflict of interest (or dual agency) situation that Savvy gets into when the Seller and Buyer are both paying for services. It's not practical for an expert to "forget" what he or she knows about an aircraft just because the logs aren't mentioned. And any organization has a limited # of experts. It's as was mentioned above regarding conflict checks with attorneys. 

Solutions would be to avoid dual-agency, or have both parties sign a form accepting it (as IIRC can be done with realty agents?). 

While I imagine most sellers understand the view of technical due diligence, the other side of the coin is having the Buyer critique every time you pick your nose... Kind of like some people with cars "there's a paint chip, I want $1000 off the price". In any case, I really don't want my info shared without my prior approval, either, for any number of sane privacy-default reasons. 

And we haven't even talked about the discrimination insurance companies can inflict with data harvesting. Think healthcare. AFAIK Savvy is not dealing with them as they are GA owner/operator-focused. But it could be coming "get a discount [ie. be able to afford insurance] if you agree to disclose". 

Anyhow, I hope this will drive some clarification of policies. I really like the service and am generally a supporter of the kind of positive entrepreneurial small business that Mike Busch represents. 

DK

 

 

 

Edited May 23 by dkkim73
mistyped word

[Shadrach]

1 minute ago, dkkim73 said:

I wonder if the deeper problem is the conflict of interest (or dual agency) situation that Savvy gets into when the Seller and Buyer are both paying for services. It's not practical for an expert to "forget" what he or she knows about an aircraft just because the logs aren't mentioned. And any organization has a limited # of experts. It's as was mentioned above regarding conflict checks with attorneys. 

Solutions would be to avoid dual-agency, or have both parties sign a form accepting it (as IIRC can be done with realty agents?). 

While I imagine most sellers understand the view of technical due diligence, the other side of the coin is having the Buyer critique every time you pick your nose... Kind of like some people with cars "there's a paint chip, I want $1000 off the price". In any case, I really don't want my info shared without my prior approval, either, so any number of sane privacy-default reasons. 

And we haven't even talked about the discrimination insurance companies can inflict with data harvesting. Think healthcare. AFAIK Savvy is not dealing with them as they are GA owner/operator-focused. But it could be coming "get a discount [ie. be able to afford insurance] if you agree to disclose". 

Anyhow, I hope this will drive some clarification of policies. I really like the service and am generally a supporter of the kind of positive entrepreneurial small business that Mike Busch represents. 

DK

All good points.  However, there is no dual agency in a situation when the buyer is a client and the seller a user of Savvy Free.  I like the idea of Savvy Free but like any free service, if you're not buying the product, you are the product.  In this case, Savvy gets to build a more robust database for model specific analysis and the uploader gets to see the data that they're giving away in a very user friendly format.

[dkkim73]

33 minutes ago, Shadrach said:

All good points.  However, there is no dual agency in a situation when the buyer is a client and the seller a user of Savvy Free.  I like the idea of Savvy Free but like any free service, if you're not buying the product, you are the product.  In this case, Savvy gets to build a more robust database for model specific analysis and the uploader gets to see the data that they're giving away in a very user friendly format.

I think there are some attorneys on MS who might have more understanding than I can generate here...

I guess if you aren't giving any consideration away then you haven't bought anything (and I generally subscribe to your point "if you're not paying you are the product"). OTOH Savvy is gaining value from this sharing of data, which, as it is portrayed, is monetized in *anonymous* ways. So the idea that data tied to your specific identity is being given for money, in ways that might be contra to you as a party in a different deal, seems different. 

Clear as mud, I've made it. I hope we hear back from Paul's inquiries. 

[PT20J]

I seriously doubt that Mike ever intended to have his prepurchase clients  access data from his other clients (free or paid) without permission. Apparently there are holes in the firewall between services. Paul @kortopates has been made aware of it and I trust it will get resolved. 

[wombat]

2 hours ago, Schllc said:

I don't believe they can make it non personally identifiable, I mean the buyer knows the seller, and Savvy cannot keep anything confidential at that point.

Sure they can make data non personally identifiable but anonymous data would not really be useful to the buyer of a specific airplane. It would be more like "Here is aggregated data about this model of aircraft and/or engine."

[Schllc]

7 minutes ago, wombat said:

Sure they can make data non personally identifiable but anonymous data would not really be useful to the buyer of a specific airplane. It would be more like "Here is aggregated data about this model of aircraft and/or engine."

Yes, aggregate, empirical data can be provided, that's true.  

but if they share specifics about data that was uploaded for a specific plane, there is no way to keep that "non identifiable"  the name is irrelevant at this juncture.

[wombat]

1 hour ago, Schllc said:

...if they share specifics about data that was uploaded for a specific plane, there is no way to keep that "non identifiable"  the name is irrelevant at this juncture.

Absolutely in agreement.   Specifics about a given plane is personally identifiable. 

[NewMoon]

On 5/22/2024 at 4:49 PM, Schllc said:

Unfortunately words are subject to interpretation, and it is difficult to word everything in a way that no one will misunderstand. Sharing data with a buyer without my consent is absolutely personally identifiable. 
When I created my account, loaded my data and looked at it, it never occurred to me that this would be shared with a prospective buyer without my consent. 
is this my fault for misunderstanding the policy?    
Probably… 
 

Now I know exactly what Savvy can do with my data, and why I posted it on this forum so everyone else understood as well.
It appears most people understood those terms exactly as I did…
This should clear up any ambiguity. 

I completely agree, i would be very taken back and would never have expected that breach. An ask for permission would have been a  very standard data release. Good grief, McDonalds won't even tell me what I ordered last week w/o a  notorized, witnessed release. 

[Will.iam]

So Savvy might want to use the same method the Military uses for its accident safety board.  Real quick the military realized that if they punished a pilot using his statement then the pilot would not tell what happened and that data would be lost and, in the interest of safety, this same issue might happen again.  In order to get the safety data the safety board needed there are two investigative teams,  They even label them the black hats and the white hats.  The white hats you tell everything that happened and there is no legal punishment that can come from your statements.  The black hats you have legal counsel with you and follow the lawyer's advise.  The white hats can not tell or give any information to the black hats.  This allows the military to get the safety info they need to possibly stop future pilots from making the same mistake as the pilots know they will not get punished from their statements, they will admit to mistakes they would not normally tell for fear of the punishment.  The black hats use the data they get from the accident to assign punishment and is also the data that can be used in a civil lawsuit if one comes up.  What keeps the white hats from talking to the black hats? This whole process only works if the trust is maintained that the white hats will not disclose the info to the black hats for if they do then they loose the trust of the pilots forever in the future and that is the whole point of the white hats to get the data that the black hats could never get if punishment was assigned based on the pilots statements.  This system works so well that I think it was the bases for the NASA reports that the FAA now uses as the military also has the statement if you tell the white hats a statement that you were committing a criminal act, intentionally destroying govt property, or lying in your statement then your whole statement can be used by the black hats.

Savvy has to establish the rules very precisely what is and is not shared and when between the two parties and not break that trust or risk people not willing to trust savvy with their data. in the grand scheme of things, I think the user data even the free account ones is worth more in the long run to savvy than the money from a prebuy client.

[Neshi]

My experience with savvy when doing a pre-buy.

After sending the info on the aircraft in question them putting the ticket on hold until they could get approval from the owner to release the data then they would use that as a data point for the prebuy.