Export Control & Sanctions

Aviation technical data is one of the most heavily export-controlled categories of information in the world. Case files can contain flight-control law behaviour, engine performance maps, structural design data, and — where a military or state aircraft is involved — data controlled as defence articles. Uploading such material to a cloud platform can itself constitute an export.

Read this before your first upload. It is not boilerplate.

The SeyAero platform is commercial software made generally available and is treated as EAR99 or as mass-market software under the US Export Administration Regulations. It contains encryption functionality using standard, publicly available algorithms (TLS, AES-256, SHA-256) and is handled under the applicable mass-market encryption provisions.

We are established in the United States and are subject to US law, including the EAR (15 CFR 730–774) and sanctions programmes administered by the Office of Foreign Assets Control (OFAC). Where we serve EU or UK customers, EU Regulation 2021/821 and the UK Export Control Order 2008 also apply to controlled technology handled through the platform.

You must not upload technical data controlled under the International Traffic in Arms Regulations (22 CFR 120–130) or the United States Munitions List, or equivalent controlled defence technology under the EU Common Military List or the UK Strategic Export Control Lists.

In practice this means the platform must not be used for occurrences involving military aircraft, military variants of civil airframes, or civil aircraft carrying ITAR-controlled mission systems, unless a separate written agreement is in place covering an approved deployment architecture and authorised-person controls.

Our standard hosting is multi-region and our personnel include non-US persons; hosting ITAR data on it without authorisation would create an unauthorised export and a deemed export. We do not accept that risk, and neither should you.

Category 9 dual-use technology (aerospace and propulsion) may be present in maintenance and design records. Before uploading, you are responsible for classifying the material, confirming that transfer to a cloud service in the tenancy region is permitted, and obtaining any licence required for access by nationals of third countries who are members of the case.

Adding a case member is a technology transfer to that person's country of nationality for deemed-export purposes. Our case membership interface exists so that you can control this; we cannot control it for you.

The platform may not be accessed from, or made available to persons ordinarily resident in, comprehensively sanctioned jurisdictions — currently Cuba, Iran, North Korea, Syria, and the Crimea, Donetsk and Luhansk regions of Ukraine — nor by any person on the OFAC SDN List, the BIS Entity List or Denied Persons List, the EU consolidated sanctions list, the UK sanctions list, or the UN consolidated list.

You represent, on each access, that neither you nor your organisation is a restricted party or owned 50% or more by one, and that you are not acting on behalf of one. We screen customer organisations and billing entities against these lists at onboarding and on an ongoing basis, and we suspend access immediately on a positive match pending resolution.

Where a sanctioned state's authority is the investigating authority under Annex 13, we will decline the engagement regardless of the humanitarian character of the investigation unless a specific licence is obtained.

• Classify material before upload and do not upload what you cannot lawfully transfer.
• Maintain records sufficient to demonstrate compliance, and provide them on lawful request.
• Control case membership with nationality and deemed-export exposure in mind.
• Notify us within twenty-four (24) hours if controlled data is uploaded in error, so we can contain and delete it.
• Do not re-export platform output in breach of the controls applicable to its underlying content.

Breach of this policy permits immediate suspension without notice and termination without refund, and may require us to file a voluntary self-disclosure with BIS, DDTC or OFAC. We will cooperate fully with regulators and will notify you of any disclosure concerning your data unless prohibited.

Questions before you upload: compliance@seyaero.com. Asking first is always cheaper than disclosing later.