Privacy and Cookie Policy

Privacy and Cookie Policy

Last Updated: July 20, 2020

Introduction

At AirMap, Inc., we care about your privacy and want you to be familiar with how we collect, use and share information in connection with the AirMap Services, as defined herein. This Privacy and Cookie Policy (the “Policy”) describes our practices in connection with  the  Personal Data that we collect, use and share through the AirMap website (currently available at www.airmap.com and www.app.airmap.io) and any successor website, on both desktop and mobile web browsers (the “Website”); through the software applications made available by us for use on or through computers and mobile devices (the “Apps”); through any drone or unmanned aircraft systems (“UAS”) that you own or operate and that are used in connection with any of our services (each, a “Drone”); and through HTML-formatted email messages that we send to you (collectively, including the Websites, the Apps and Drones, the “Services”). By providing Personal Data to us or using our Services, you agree to the terms and conditions of this Policy and to us collecting, holding, using and disclosing your Personal Data in accordance with it.

This Privacy and Cookie Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy and Cookie Policy.

It is important that you read this Privacy and Cookie Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy and Cookie Policy supplements other notices and privacy policies and is not intended to override them.

Particularly Important Information

  • Who We Are: AirMap is made up of different legal entities, details of which can be found below:

AirMap, Inc.
409 Santa Monica Blvd., Suite 2A
Santa Monica, CA 90401 USA

AirMap Deutschland GmbH
22 Fritz-von-Weidenback-Straße
Miesbach BY 83714, Germany

AirMap Switzerland GmbH
c/o Zedra Trust Company (Suisse) SA
Branch Office Zurich
Gartenstrasse 23
8002 Zurich, Switzerland

AirMap France SAS
37-59 Avenue Ledru Rollin
75012 Paris, France

AirMap Singapore Pvt Limited
50 Raffles Place
#32-01 Singapore Land Tower
Singapore 048623

Hangar Technology, Inc.
110 Wild Basin Road, Ste. 150
Austin Texas, 78746

This Privacy and Cookie Policy is issued on behalf of the AirMap Group so when we mention “AirMap”, “we”, “us” or “our” in this Privacy and Cookie Policy, we are referring to the relevant company in the AirMap Group responsible for processing your data. For purposes of applicable data protection legislation, the data controller of your Personal Data is:

AirMap, Inc.
409 Santa Monica Blvd., Suite 2A
Santa Monica, CA 90401 USA

  • Contact details: If you have any questions about this Privacy and Cookie Policy, including any requests to exercise your rights, you may contact us at:

Attn: Compliance Team
AirMap, Inc.
409 Santa Monica Blvd., Suite 2A
Santa Monica, CA 90401 USA
compliance‌@airmap.com

  • Changes to this Policy: We will post any modifications or changes to the Policy on our website. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our website prior to such changes taking effect.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. The Data We Collect About You

As used in this Policy, “Personal Data” includes (i) any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number; or (ii) an opinion about an identified individual or an individual who can be reasonably identified from the opinion, regardless of whether such opinion is true. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, photo, pilot registration number, a copy of a driver’s license or government ID, operator ID, age, or social media account ID.
  • Contact Data includes billing and/or physical address, email address and telephone numbers.
  • Drone Data includes a drone’s physical location, including its flight path or telemetry data, a serial number, UAS ID, operation descriptions, or other information that identifies the Drone.
  • Employment Data includes data about your professional life such as Curriculum Vitae or cover letter.
  • Financial Data includes bank account and payment card details.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Technical Data includes internet protocol (IP) address, your Media Access Control (MAC) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, your interactions with the apps or website, and other technology on the devices you use to access this Website, our App, or our Services.
  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
  • Usage Data includes information about how you use our Website, App, and Services.
  • User Generated Data includes the personal information that may be contained in any video, comment or other submission you upload or post to the Services.

If you fail to provide personal data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

2. How is Your Personal Data Collected

We collect information about you in the following ways:

Information You Give Us Directly. This includes:

  • Identity, Contact, and Financial Data when you register to use our Services;
  • User Generated Data that may be contained in any video, comment or other submission you upload or post to the Services;
  • Identity and Contact Data you provide in connection with participating in our contests, sweepstakes, and other promotions we run with the Services;
  • Identity and Contact Data you provide when you report a problem with the Services, ask us to contact you or when we provide you with customer support;
  • Identity, Contact, Financial, and Transaction Data you provide to us when you make a purchase through the Services; and
  • Identity and Contact Data you provide to us when you correspond with us by phone, email or otherwise; and
  • Drone Data you provide when you operate a Drone; and
  • Marketing and Communications Data, such as your preferred means of communicating with us, when you voluntarily provide it.

Information We Receive from Social Networking Sites. Our Services include(s) interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.

Information We Receive from Other Sources. We may also collect information about you from the following other sources:

  1. Technical Data from analytics providers such as Google based in the United States;
  2. Contact, Financial and Transaction Data from providers of technical and payment services;
  3. Identity and Contact Data from data brokers and aggregators.
  4. Identity and Contact Data from your friends and other people with whom you are connected on social media platforms;
  5. Drone, Identity and Contact Data from our developers, if you have agreed to share your information with them;
  6. Identity and Contact Data from your friends and other people with whom you are connected on social media platforms;
  7. Drone Data from drone manufacturers and our developer partners.

Information We Collect Automatically. We automatically Identity, Technical and Usage Data about you and your computer or mobile device when you access the Services from our computer and/or our App.

3. Cookies

What Are Cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits the Services; and (2) third party cookies, which are served by service providers on the Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies We Use
Our Services use the following types of cookies for the purposes set out below:

Type of Cookie Purpose
Essential Cookies These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies These cookies are used to collect information about traffic to the Services and how users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.
We may use Google Analytics or similar tools for this purpose. Google Analytics or similar tools uses their own cookies. We only use these tools to improve how our Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Disabling Cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit.

4. Flash Technology

We may also use Flash cookies (which are also known as Flash Local Shared Object (“LSOs”)) on our Services] to collect and store information about your use of our Services. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also control Flash LSOs by going to the Global Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Services.

5. Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ Personal Data.

6. Do Not Track Signals

We also may use cookies and other tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.

7. Using Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your Personal Data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message, or as otherwise required under applicable law. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and, if you are based in the European Union, which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer and allow you to use our Services (a) Identity
(b) Contact
(c) Drone
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you (to process your purchases, provide you Services, send you updates, deliver and manage your order/Services, including to collect payments, fees and charges)

(b) Necessary for our legitimate interests (to start legal proceedings to recover debts due to us)

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you (to inform you of any changes to our terms and conditions)
(b) Necessary to comply with a legal obligation (to inform you of any changes to our privacy policy)
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Services)
To verify your identity in connection with your use of a drone/your account (a) Identity Necessary for our legitimate interests (to prevent fraud in connection with the use of our Services)
To provide you with information about your drone, including location-based information, or its intended flight path, including access to authorizations from applicable authorities for particular areas and information about various advisories. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(g) Drone
Performance of a contract
To administer and protect our business, our Services, this Website and our App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Website/App content to you, including to provide you with personalized location based service content. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website/App, Services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our Services, to keep our Website/App updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our Services and grow our business)
To communicate with you by email, text, social media messaging, social media posting or any other communication mechanism that you choose (a) Identity
(b) Contact
(c) Marketing and Communications
Necessary for our legitimate interests (to reply to communications sent to us and for customer relationship management purposes)
Provide you with the ability to upload or post videos, comments, or other submissions to our Services (a) Identity
(b) Contact
(c) User Generated
Necessary for our legitimate interests (to facilitate exchange of content in the drone community)
To enable you to publicly share your flight with others. You may choose to turn this feature off by editing your general settings in the app and deselecting the option to “Make My Flight Public.” (a) Drone Necessary for our legitimate interests (to provide awareness of drone flights to the drone community)
To enable you to partake in a prize draw, competition or other promotion we run with our Services, or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our Services, to develop them and grow our business)

Provide you with support on our Services (a) Identity
(b) Contact
(c) Marketing and Communications
(d) Technical
Performance of a contract with you
To respond to your inquiries related to employment opportunities (a) Identity
(b) Contact Data
(c) Employment
Performance of a contract with you or in order to take steps at your request prior to entering into a contract with you

Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing. We have established the following Personal Data control mechanisms:

Promotional offers from us.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased or used Services from us and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of service purchase, service experience or other transactions.

Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Sharing Your Personal Data

We may share your Personal Data as follows:

  • Third Parties Designated by You. We may share your Personal Data with third parties where you have requested that we do so, where your actions justify us to share that information for purposes of the Services, or where you have provided your consent for us to do so. That may include:
    • Airports, air navigation service providers, civil aviation authorities, or other airspace managers that have an AirMap UTM Dashboard, EOM or other account pursuant to https://www.airmap.com/utm-dashboard-dnas-terms-service/ (“Dashboard user”), for example, when you provide notice of a nearby operation, where your flight intersects with a certain jurisdiction where an Dashboard User is located and we inform the dashboard user of your flight, or when you request authorization to operate;
    • other users, such as to anyone to whom you send messages through the Services; and
    • messaging or social services, such as message boards, chat, profile pages, blogs and other services to which you are able to post information and materials or communicate with other users of the Services (please note that any information you post or disclose through these services may become public and may be available to users of the Services and to the general public);
    • your friends or contacts associated with your social media account, other website users and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account.
    • By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Data shared with other users or with your social media account provider, please do not connect your social media account with your Services account, and do not participate in social sharing on the Services.
  • Our Third Party Service Providers and Developers. We may share your Personal Data with our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. We may also share your Personal Data with our developers to provide services to you. These third parties are only permitted to use your Personal Data on our behalf and instructions and to the extent necessary to enable them to provide their services to us and you. They are required to comply with applicable data privacy law and to implement appropriate security measures to protect your Personal Data.
    • If you make a payment through the Services, your Personal Data may be collected by a third party, and not by us, and will be subject to the third party’s privacy policy, rather than this Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Data.
    • If you submit any Personal Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
  • Third Party Advertisers. We may share with your consent Personal Data with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
  • Third Party Sponsors of Sweepstakes. We may share Personal Data with sponsors for sweepstakes, contests and similar promotions which you choose to participate.
  • Affiliates. We may share some or all of your Personal Data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share Personal Data with our affiliates where you wish to receive marketing communications from us  and such marketing communications are served by or using our affiliates.
  • Corporate Restructuring. We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • Drone Manufacturers. We may share Personal Data with the manufacturer in connection with the operation of your Drone.
  • Other Disclosures. We may share Personal Data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements, including public and government authorities outside your country of residence; (c) to enforce our Policy; (d) to enforce our terms and conditions; (e) to protect our rights, privacy, safety or property, and/or that of you, our affiliates or others; (f) to allow us to pursue available remedies or limit the damages that we may sustain; (g) with your express consent to the disclosure or where your consent may be reasonably inferred from the circumstances.

9. Aggregated/Anonymous Data

When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.

We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyses usage patterns in order to make improvements to our Services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website or App feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy and Cookie Policy.

10. Third Party Sites

Our Services may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.

11. User Generated Content

You may share Personal Data with us when you submit user generated content to our Services, including via any promotion, forums, message boards, and blogs on our Services. Please note that any information you post or disclose on our Services will become public information, and will be available to other users of our Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Data, or any other information, on our Services. Such Personal Data and other information will not be private or confidential once it is published on our Services.

If you provide feedback to us, we may use and disclose such feedback on our Services, provided we do not associate such feedback with your Personal Data.

12. International Data Transfer

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.

ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures here.

Where we use service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

ADDITIONAL INFORMATION REGARDING AUSTRALIAN USERS: If you are a resident of Australia please note that your personal information may be disclosed to overseas recipients within the AirMap Group (see list of entities and countries in the Introduction to this Policy) as well as to our service providers outside of Australia.

13. Security

We have put in place appropriate organizational, technical and administrative measures to protect Personal Data within our organization. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 19 below. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. Retention

We will only retain your Personal Data as long as reasonably required for you to use and provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes).

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Section 17, “Your Rights” below for further information.

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

15. Our Policy on Children

Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without parental consent, he or she should contact us using the details in Section 19 below. We will delete such information from our files as soon as reasonably practicable.

16. Sensitive Personal Data

We do not collect and ask that you please do not send us or otherwise  disclose to us through the Services or any Website functionality allowing you to upload or post videos, comments and other user generate content on our Website and App, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership).  We also do not collect nor expect to receive from you any information about criminal convictions and offences.

17. Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights:

If you wish to exercise any of these rights, please contact us using the details in Section 19 below. In your request, please make clear: (i) what Personal Data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

18. Complaints

We are committed to resolve any complaints about our collection or use of your Personal Data. If you would like to make a complaint regarding this Policy or our practices in relation to your Personal Data, please contact us at: compliance‌@airmap.com. We will reply to your complaint as soon as we can. We hope to resolve any complaint brought to our attention.

If you are based in Australia or the European Union, please note that you have the right to make a complaint at any time to your national regulator for data protection issues (the Office of the Australian Information Commissioner at www.oaic.gov.au if you reside in Australia, or the relevant Data Protection Authority in your country of residence if you reside in the EU). We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

19. Contact Information

We welcome your comments or questions about this Policy. You may contact us at compliance‌@airmap.com or:

Attn: Compliance Team
AirMap, Inc.
409 Santa Monica Blvd., Suite 2A
Santa Monica, CA 90401 USA

20. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of Personal Data relating to you.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://www.airmap.com/privacy-notice-for-california-residents/.

Your Nevada Privacy Rights
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: compliance@airmap.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.