Last updated: 1/27/2015

We self-certify compliance with:

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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 Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles that FlyData follows with respect to personal information transferred from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein, and Norway) and from Switzerland to the United States.

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. Companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, FlyData adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).

Consistent with its commitment to protect personal privacy, FlyData Inc. complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. FlyData Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view FlyData’s certification, please visit http://www.export.gov/safeharbor/.

SCOPE

This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by FlyData in the United States from the European Economic Area and from Switzerland, in any format, including electronic, paper or verbal.

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 disclose 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 non-public 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.

PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the Safe Harbor Principles.

NOTICE: Where FlyData collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, 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 EEA, 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.

FlyData will provide individuals with reasonable mechanisms to exercise their choices.

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: FlyData will obtain assurances from their agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where FlyData become 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.

ACCESS AND CORRECTION: 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.

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, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with these Principles.

DISPUTE RESOLUTION:

Any questions or concerns regarding the use or disclosure of personal information should be directed to FlyData at the address given below. FlyData will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.

FlyData has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, 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 the BBB EU SAFE HARBOR website for more information and to file a complaint.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by FlyData to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

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

FlyData Inc.
1043 N. Shoreline Blvd. Suite #200
Mountain View, CA 94043
Telephone: (855) 427-9787
E-mail Address: admin@flydata.com

CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

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

EFFECTIVE DATE: 1/27/2015


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