Privacy Policy Last updated: 12/22/2016
We self-certify compliance with: EU US Privacy Shield

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FlyData Inc. (hereinafter the “FlyData”) respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. FlyData strives to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, and pride themselves on upholding the highest ethical standards in their business practices. This Privacy Shield Privacy Policy (the “Policy”) sets forth the privacy principles that FlyData follows with respect to personal information transferred from the European Economic Area (EU)) and from Switzerland to the United States.
The United States Department of Transportation is the enforcement authority with jurisdiction over this compliance with the Privacy Shield.

SCOPE

This PRIVACY SHIELD Privacy Policy (the “Policy”) applies to all personal information electronically received by FlyData in the United States from European Economic Area member countries.

DEFINITIONS For purposes of this Policy, the following definitions shall apply: “Agent”​means any third party that collects or uses personal information under the instructions of, and solely for, FlyData or to which FlyData discloses personal information for use on their behalf. “Personal information”​means any information or set of information that identifies or is used by or on behalf of FlyData to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with nonpublic personal information. “Sensitive personal information”​means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns an individual’s health or sex life. In addition, FlyData will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive. “The Company”​means FlyData Inc. and their respective successors, subsidiaries, divisions and groups in the United States.

FlyData complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Economic Area member countries. FlyData has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recorse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov

FlyData complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. FlyData has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern. To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/

TYPES OF PERSONAL DATA WE COLLECT AND HOW IT IS USED

Email address for providing service.

PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the PRIVACY SHIELD Principles.

NOTICE​:

Where FlyData collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses an individual’s personal information, the types of non–agent third parties to which FlyData discloses that information, the choices and means, if any, FlyData offers individuals for limiting the use and disclosure of personal information about them, and how to contact FlyData. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to FlyData, or as soon as practicable thereafter, and in any event before FlyData uses or discloses the information for a purpose other than that for which it was originally collected. Where FlyData receives personal information from their subsidiaries, affiliates or other entities in the EU, they will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE​:

FlyData will offer individuals the opportunity to choose (opt out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, FlyData will give individuals the opportunity to affirmatively and explicitly (opt in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. To limit the use and disclosure of their personal data, an EU individual may submit a written request to support@flydata.com.

DATA INTEGRITY​:

FlyData will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. FlyData will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS and Other Third Parties​:

FlyData does not transfer data to third parties who are not acting as their agents.
Where FlyData becomes aware that an agent is using or disclosing personal information in a manner contrary to this Policy, FlyData will take reasonable steps to prevent or stop the use or disclosure. FlyData, Inc. is liable for appropriate onward transfers of personal data to third parties.

ACCESS AND CORRECTION:​

FlyData acknowledges the right of individuals to have access to their personal information. Upon request, FlyData will grant individuals reasonable access to personal information that it holds about them. In addition, FlyData will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to support@flydata.com. If requested to remove data, we will respond within a reasonable timeframe.

SECURITY​:

FlyData will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT​:

FlyData uses a self- assessment approach to maintain compliance with this privacy policy and periodically verifies that the policy is accurate, prominently displayed, completely implemented and accessible and in conformity with these Principles.

CONTACT INFORMATION:

In compliance with EU US Privacy Shield, FlyData commits to resolve complaints about your privacy and our collection or use of your personal information. European Economic Area individuals with inquiries or complaints regarding this privacy policy should first contact FlyData at:

FlyData Inc.
440 N Wolfe Rd Sunnyvale, CA 94085
Telephone: (855) 427-9787
E-mail Address: support@flydata.com

DISPUTE RESOLUTION:​

FlyData has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. 

In limited situations and as a last resort, individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

In compliance with the US-Swiss Safe Harbor Principles, FlyData commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this privacy policy should first contact FlyData at:

FlyData Inc.
440 N Wolfe Rd Sunnyvale, CA 94085
Telephone: (855) 427-9787
E-mail Address: support@flydata.com

FlyData has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

LIMITATION ON APPLICATION OF PRINCIPLES

Please note that FlyData may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements

CHANGES TO THIS PRIVACY SHIELD PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the PRIVACY SHIELD Principles. A notice will be posted on FlyData’s web page (www.flydata.com) whenever this PRIVACY SHIELD Privacy Policy is changed in a material way.


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