Privacy Policy (updated 22/03/2017)

BACKGROUND

This privacy policy ("Policy") applies as between you, the User of this Website or Mobile Application, and Altitude Angel Limited, the owner and provider of this Website or Mobile Application. This Policy applies to our processing and use of any and all Data collected by us in relation to your use of the Website or Mobile Application. Please read the following carefully to understand our views and practices regarding your personal Data and how we will treat it. By visiting the Website or the Mobile Application you are accepting and consenting to the practices described in this Policy.

We also advise that you read this Policy alongside our terms and conditions, which you can find at https://www.altitudeangel.com/TermsAndPolicies/Terms. In the event of any conflict or discrepancy, the rights and obligations set out in our terms and conditions supersede those set out in this Policy.

For the purpose of the Data Protection Act 1998, the data controller is Altitude Angel Limited of Davidson House, The Forbury, Reading, England, RG1 3EU.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

"Data" means collectively all information that you submit to Altitude Angel via the Website or the Mobile Application, as set out in clause 3.2. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998;

"Cookie" means a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in Clause 12;

"Group" means in relation to a company, that company, any subsidiary or any holding company from time to time of that company, and any subsidiary from time to time of a holding company of that company. Each company in a Group is a member of the Group.

"Mobile Application" means any officially-branded first-party Mobile Application authorised by Us, and properly distributed and obtained through the Apple App Store, the Google Play Store, the Windows Store or any other store that we may from time to time choose to distribute to;

"Service" means the Altitude Angel goods and services that We provide to Users through the Website and the Mobile Application;

"Us", "Altitude Angel" means Altitude Angel Limited incorporated and registered in England and Wales with company number 09350032 and whose registered address is at of Davidson House, The Forbury, Reading, England, RG1 3EU;

"UK and EU Cookie Law" means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

"User" means any third party that accesses the Website or the Mobile Application that is not employed by Altitude Angel and acting in the course of their employment; and

"Website" means the website that we host at https://www.altitudeangel.com and any sub-domains of this site and/or officially branded/licensed first-party properties of Altitude Angel unless expressly excluded by their own terms and conditions.

2. Scope of this Policy

This Policy applies only to the actions of Altitude Angel and Users with respect to the Website and the Mobile Application. It does not extend to any websites or mobile applications that can be accessed from this Website or Mobile Application including, but not limited to, any links we may provide to social media websites.

3. Data Collected

When you use the Website or the Mobile Application to access our Service, we will collect and process Data about you. Some data will be mandatory and we will require you to provide that to us, as set out in clause 3.1 below, and other Data will be automatically supplied to us when you use the Service, as set out in clause 3.2 below.

a. Mandatory Data you give us. This is Data about you that you give us by accessing and using our Website or by corresponding with us by phone, e-mail or otherwise. It includes Data you provide when you register to use our Website and/or Mobile Application, subscribe to our Service and when you report a problem with our Website and/or Mobile Application. Such Data may include:

i. your name ;

ii. profession (whether you are a professional drone operator, or not);

iii. contact information such as email addresses and telephone numbers;

iv. demographic information such as your location and data about your drones and how you fly them;

v. information about your device; and

vi. information about your drone (including unique identification).

b. Data we collect about you.

With regard to each of your visits to our Website and/or Mobile Application and your use of the Service, we will automatically collect the following Data:

- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, web browser type and version and operating system and platform;

- information about your visit, including URLs starting with a referring site, your activity on this Website and the site you exit to, analytics about your use of our Drone Safety Map, a list of errors that have occurred associated with your visit (if any) and performance information about how well our Website pages were delivered;

- data in respect of your location / GPS;

- unique application numbers (for example, when you install or uninstall the Service containing a unique application number or when the Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us); and

- any other data that may be generated by or used by the Website or the Mobile Application.

Some features of our Website or Mobile Applications may optionally allow you to give us additional data. The following data will never be collected without your explicit consent:

- information about your drone including drone log data, real time drone telemetry and/or drone flights made or to be made;

- information about the device upon which you access and use the Service;

- payload data;

c. We will collect and store Data on your device using application data caches and browser web storage (including HTML 5) and other technology that we may from time to time use.

4. Our Use of Data

a. Any Data you submit will be retained by Altitude Angel until the termination of your Altitude Angel account, for whatever reason. Please note that we will only usually terminate your account if you breach our terms and conditions or if you remain inactive on our Service for a period of time, usually two years. You may also ask us to delete your Data at any time, by contacting us at hello@altitudeangel.com. Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties.

This excludes: our partners, affiliates and/or other companies within our Group from time to time and

ii. other Users who may access and use your Data for safety planning purposes; and

iii. fully anonymised Data that we may send to third parties for the purpose of market research.

c. All Data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see Clause 11 below.

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website and Mobile Application. Specifically, Data that you provide to us may be used by us for the following reasons: to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;

ii. to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;

iii. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;

iv. transmission by email, text or Mobile Application notification of promotional materials we feel may interest you;

v. to notify you about changes to our Website, Mobile Application and/or our Service;

vi. to ensure that content from our Website and Mobile Application is presented in the most effective manner for you and for your computer;

vii. contact for market research purposes which may be done using email, telephone or mail. Such information may be used to customise or update the Website and/or Mobile Application;

viii. to deliver our services to Users.

e. We may also use the Data that we collect about you for the following reasons:

i. to administer our Website and Mobile Application and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

ii. to improve our Website and Mobile Application to ensure that content is presented in the most effective manner for you and for your computer or mobile device;

iii. to allow you to participate in interactive features of our Service, when you choose to do so;

iv. as part of our efforts to keep our Website and Mobile Application safe and secure;

v. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

vi. to make suggestions and recommendations to you and other Users of our Website and Mobile Application about goods or services that may interest You or them; and

vii. to combine the Data with data received from third parties for all of the purposes set out in this clause 4.

5. Third Party Websites and Services

a. Altitude Angel may, from time to time, employ the services of third parties for dealing with matters that may include, but are not limited to, payment processing, delivery of purchased items, search engine facilities, advertising and marketing. The providers of such services may have limited access to certain Data provided by Users of the Website and Mobile Application.

b. Any Data used by such third parties is used only to the extent required by them to perform the services that Altitude Angel requests. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties shall be processed within the terms of this Policy and in accordance with the Data Protection Act 1998.

c. If you require any further information regarding what Data may be provided to such third parties, please contact us by email at hello@altitudeangel.com and we will be happy to assist.

6. Links to Other Websites

This Website may, from time to time, provide links to other websites. Altitude Angel has no control over such websites and is in no way responsible for the content thereof. This Policy does not extend to your use of such websites. Users are advised to read the privacy policy or statement of other websites prior to using them.

7. Changes of Business Ownership and Control

a. Altitude Angel may, from time to time, expand or reduce our business. This may involve the sale and/or the transfer of control of all or part of Altitude Angel, or a third party acquiring substantially all of its assets. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling or acquiring party will, under the terms of this Policy, be permitted to use the Data solely for the purposes for which it was originally supplied to us.

b. In the event that any Data submitted by Users is to be transferred in such a manner, we will use our reasonable efforts to inform you but make no guarantee to do so and you may not be contacted in advance a transfer. All contact will be for informative purposes only. If you wish to have your Data deleted, you will need to contact us by email at hello@altitudeangel.com or to any other email address as we may provide to you.

8. Controlling Use of Your Data

a. Wherever You are required to submit Data, You will be given notifications and options regarding our use of that Data. This may include the following:

8.1.1 use of Data for direct marketing purposes; and

8.1.2 sharing Data with third parties.

b. You may also ask us to remove Your Data at any time by contacting us by email at hello@altitudeangel.com. You accept that removed Data will remain on our back-up systems for a short period of time and will thereafter be permanently removed.

9. Your Right to Withhold Information

a. You may access certain areas of the Website and Mobile Application without providing any Data at all. However, to use all features and functions available on the Website and Mobile Application you may be required to submit certain Data. For example, you are required to create a free account in order to fully utilise our Drone Safety Map or any Mobile Application.

b. You may restrict your internet browsers use of Cookies. For more information see Clause 12. If you do this, our Website may become unusable.

10. Accessing your own Data

You have the right to ask for a copy of any of your Data held by Altitude Angel (where such data is held) on payment of a small fee which we shall notify to you and which will not exceed 25.

11. Security and Storage

a. Data security is of great importance to Altitude Angel and to protect your Data we have put in place physical, electronic and managerial procedures to safeguard and secure Data collected via the Website and/or Mobile Application in accordance with best-practices.

b. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

c. The Data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. This includes staff engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your Data, you agree to this transfer, storing or processing.

d. All information you provide to us is stored on our secure servers. We also use Microsoft Azure and Amazon Web Services as our cloud platform providers. Any payment transactions will be encrypted and handled by a reputable payment company. Altitude Angel will not store any payment information on its servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website or Mobile Application, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

e. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Website or Mobile Application; any transmission is at your own risk. Once we have received your Data, we will use strict procedures and security features to try to prevent unauthorised access.

12. Cookies

a. This Website may place and access certain Cookies on your computer. Altitude Angel uses Cookies to improve your experience of using the Website and to improve our Service. Altitude Angel has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

b. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law, as amended from time to time.

c. The Website places Cookies on your computer explicitly. You will be notified upon first visit to our Website via a popup at the bottom of the screen. Our cookies enable us to provide the best possible service to you. You may configure your browser to reject them, in which case many features of the site will become unusable.

d. Certain features of the Website depend upon Cookies to function. UK and EU Cookie Law deems these Cookies to be strictly necessary. These Cookies are shown below. Your consent will not be sought to place these Cookies, but you may still block these cookies by changing your internet browsers settings as detailed below.

e. This Website places the following Cookies (first party cookies):

Name: cookiesDirective. Purpose: Records whether or not you have seen our EU Cookies Directive warning. This is Strictly Necessary.

Name: AspNet.Application.Cookie. Purpose: This cookie is required in order to maintain your logged-in user session. Strictly Necessary when you are logged-in.

f. This Website uses analytics services provided by Google and Microsoft. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling us to better understand how Users use the Website. This, in turn, enables us to improve the Website and the products and services offered through it. You do not have to allow us to use these Cookies, as detailed below, however whilst our use of them does not pose any risk to your privacy or your safe use of the Website it does enable us to continually improve our business.

g. The analytics services used by this Website use Cookies to gather the required information. Certain of these Cookies may be placed immediately when you decide to visit the Website and it may not be possible to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below.

h. The analytics services used by this Website use the following Cookies:

Names: ai_user and ai_authUser. Third party cookies. Set by Microsoft Application Insights to enable us to perform user analytics and provide technical support.

Name: _ga. This cookie is set by Google Analytics and allows us to gather usage information for the purposes of marketing and service improvement.

Name: ai_session. Third party. This cookie is set by Microsoft Application Insights, a tool we use for monitoring our Website for faults. This cookie helps us to determine if a specific user has faults, so we can provide a better support experience.

i. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

j. You can choose to delete Cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

k. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

13. Changes to this Policy

Altitude Angel reserves the right to change this Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and Mobile Application, and you are deemed to have accepted the terms of the Policy on your first use of the Website or Mobile Application following the alterations.

14. Contact

Questions, comments and requests regarding this Policy are welcomed and should be addressed to us by email at hello@altitudeangel.com.