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.
TYPES OF PERSONAL DATA WE COLLECT AND HOW IT IS USED
Email address for providing service.
The privacy principles in this Policy are based on the PRIVACY SHIELD Principles.
Where FlyData collects personal information directly from individuals in the EU or Switzerland, 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 or Switzerland, 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.
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 or Swiss individual may submit a written request to email@example.com.
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 or Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to firstname.lastname@example.org. If requested to remove data, we will respond within a reasonable timeframe.
FlyData will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.
FlyData is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, FlyData commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact FlyData at:
440 N Wolfe Rd Sunnyvale, CA 94085
Telephone: (855) 427-9787
E-mail Address: email@example.com
FlyData has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, 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. This service is provided free of charge to you.
If your Privacy Shield complaint is not satisfactorily addressed, and your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, FlyData commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction.
Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction
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