Privacy Policy of EasyVFR 4 website and application

Full policy

Owner and Data Controller

The PocketFMS Foundation
Emoeweg 28
8218PC Lelystad
THE NETHERLANDS

Owner contact email: team@easyvfr4.aero

Types of Data collected

Among the types of Personal Data that EasyVFR 4 website and application collects, by itself or through third parties, there are: Cookies; Usage Data; email address; User ID; various types of Data; first name; last name; address; username; password; VAT Number; company name; country; ZIP/Postal code; city; picture; profile picture; billing address; house number; language; device logs; device information; app information; Data communicated while using the service; payment data; Precise location permission (non-continuous); Sensors permission; Storage permission; Motion sensors permission; geographic position; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using EasyVFR 4 website and application.
Unless specified otherwise, all Data requested by EasyVFR 4 website and application is mandatory and failure to provide this Data may make it impossible for EasyVFR 4 website and application to provide its services. In cases where EasyVFR 4 website and application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by EasyVFR 4 website and application or by the owners of third-party services used by EasyVFR 4 website and application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through EasyVFR 4 website and application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of EasyVFR 4 website and application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Contacting the User, Data transfer outside the EU, Registration and authentication provided directly by EasyVFR 4 website and application, Beta Testing, SPAM protection, Traffic optimization and distribution, Content commenting, Managing support and contact requests, Managing contacts and sending messages, Displaying content from external platforms, Handling payments, Device permissions for Personal Data access, Tag Management, Remarketing and behavioral targeting, Platform services and hosting, Managing data collection and online surveys, Location-based interactions, Interaction with data collection platforms and other third parties, Hosting and backend infrastructure, Selling goods and services online and Backup saving and management.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

Depending on the User's specific device, EasyVFR 4 website and application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of EasyVFR 4 website and application.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by EasyVFR 4 website and application.

Motion sensors permission

Used for accessing the User's device motion sensors to measure the User's activity such as step counts, stairs climbed, and movement type (walking, cycling, etc.).

Precise location permission (non-continuous)

Used for accessing the User's precise device location. EasyVFR 4 website and application may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for EasyVFR 4 website and application to derive the exact position of the User on a continuous basis.

Sensors permission

Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Analytics collected directly (EasyVFR 4 website and application)

  EasyVFR 4 website and application uses an internal analytics system that does not involve third parties.

  Personal Data processed: Cookies; Usage Data.

  Category of personal information collected according to CCPA: internet information.

  User ID extension for Google Analytics (Google LLC)

  Google Analytics on EasyVFR 4 website and application makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
  The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by EasyVFR 4 website and application.
  The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.

  Personal Data processed: Cookies.

  Place of processing: United States – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Analytics (Google Ireland Limited)

  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of EasyVFR 4 website and application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)

  Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Facebook advertising network with actions performed on EasyVFR 4 website and application. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Analytics Demographics and Interests reports (Google Ireland Limited)

  Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for EasyVFR 4 website and application (demographics means age and gender Data).

  Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

  Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Backup saving and management

  This type of service allows the Owner to save and manage backups of EasyVFR 4 website and application on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to EasyVFR 4 website and application.

  EasyVFR cloud

  Automatically :
  EasyVFR stores routes, filed flightplans and aircraft profiles to servers located in the Netherlands owned by PocketFMS whenever there is an internet connection available and the associated item is saved.
  
  Manually:
  Logbook (includes tracking details), user waypoints, breadcrumb details are only stored on EasyVFR cloud when explicitly executed by the user.

• Beta Testing

  This type of service makes it possible to manage User access to EasyVFR 4 website and application, or parts of it, for the purpose of testing a certain feature or the entire Application.
  The service provider may automatically collect data related to crashes and statistics related to the User's use of EasyVFR 4 website and application in a personally identifiable form.

  Google Play Beta Testing (Google LLC)

  Google Play Beta Testing is a beta testing service provided by Google LLC.

  Personal Data processed: device information; device logs; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  TestFlight (Apple Inc.)

  TestFlight is a beta testing service provided by Apple Inc.

  Personal Data processed: app information; device information; device logs; email address; Usage Data; username.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Contacting the User

  Contact form (EasyVFR 4 website and application)

  By filling in the contact form with their Data, the User authorizes EasyVFR 4 website and application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: email address; User ID.

  Category of personal information collected according to CCPA: identifiers.

  Mailing list or newsletter (EasyVFR 4 website and application)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning EasyVFR 4 website and application. Your email address might also be added to this list as a result of signing up to EasyVFR 4 website and application or after making a purchase.

  Personal Data processed: email address; first name; last name; Tracker.

  Category of personal information collected according to CCPA: identifiers; internet information.

  MailPoet newsletter & emails

  If you have subscribed to our newsletter or if you are a member of our website (you can log in) or if you have purchased on our website, there is a good chance you will receive emails from us.
  
  We will only send you emails which you have signed up to receive, or which pertain to the services we provided to you.
  
  To send you emails, we use the name and email address you provide us. Our site also logs the IP address you used when you signed up for the service to prevent abuse of the system.
  
  No identifiable information is otherwise tracked outside this website except for the email address.

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of EasyVFR 4 website and application.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (EasyVFR 4 website and application)

  EasyVFR 4 website and application has its own internal content comment system.

  Personal Data processed: email address; first name; last name; Tracker; Usage Data; username.

  Category of personal information collected according to CCPA: identifiers; internet information.

  Disqus (Disqus)

  Disqus is a hosted discussion board solution provided by Disqus that enables EasyVFR 4 website and application to add a commenting feature to any content.

  Personal Data processed: Data communicated while using the service; Tracker; Usage Data.

  Place of processing: United States – Privacy Policy – Opt out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on standard contractual clauses (EasyVFR 4 website and application)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
  This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

  Data transfer to countries that guarantee European standards (EasyVFR 4 website and application)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
  The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

• Device permissions for Personal Data access

  EasyVFR 4 website and application requests certain permissions from Users that allow it to access the User's device Data as described below.

  Device permissions for Personal Data access (EasyVFR 4 website and application)

  EasyVFR 4 website and application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

  Personal Data processed: Motion sensors permission; Precise location permission (non-continuous); Sensors permission; Storage permission.

  Category of personal information collected according to CCPA: internet information; geolocation data.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of EasyVFR 4 website and application and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts (Google Ireland Limited)

  Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows EasyVFR 4 website and application to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Font Awesome (Fonticons, Inc. )

  Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows EasyVFR 4 website and application to incorporate content of this kind on its pages.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Gravatar (Aut O’Mattic A8C Ireland Ltd.)

  Gravatar is an image visualization service provided by Aut O’Mattic A8C Ireland Ltd. that allows EasyVFR 4 website and application to incorporate content of this kind on its pages.
  Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.

  Personal Data processed: email address; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  YouTube video widget (Google Ireland Limited)

  YouTube is a video content visualization service provided by Google Ireland Limited that allows EasyVFR 4 website and application to incorporate content of this kind on its pages.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Handling payments

  Unless otherwise specified, EasyVFR 4 website and application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. EasyVFR 4 website and application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  Mollie payment provider

  Payments (other than bank transfer) are processed by Mollie. For details regarding data storage and privacy we refer to their website: https://www.mollie.com/en/privacy

  Payment by bank transfer (EasyVFR 4 website and application)

  In the event that the chosen payment method is a direct bank transfer to the current account indicated by EasyVFR 4 website and application, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.

  Personal Data processed: address; company name; first name; last name; payment data.

  Category of personal information collected according to CCPA: identifiers; commercial information.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable EasyVFR 4 website and application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of EasyVFR 4 website and application.

  Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  GitHub Pages (GitHub Inc.)

  GitHub Pages is a hosting service provided by GitHub, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of EasyVFR 4 website and application for the purpose of saving and reusing data.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  Typeform widget (TYPEFORM S.L)

  The Typeform widget is a service for interacting with the Typeform data collection platform provided by TYPEFORM S.L.

  Personal Data processed: Data communicated while using the service; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Spain – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Location-based interactions

  Non-continuous geolocation (EasyVFR 4 website and application)

  EasyVFR 4 website and application may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by EasyVFR 4 website and application.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data processed: geographic position.

  Category of personal information collected according to CCPA: geolocation data.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Mailchimp (The Rocket Science Group LLC)

  Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.

  Personal Data processed: email address; first name; last name; username.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Mailgun (Mailgun Technologies, Inc.)

  Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.

  Personal Data processed: email address; Tracker; various types of Data.

  Place of processing: Germany – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Managing data collection and online surveys

  This type of service allows EasyVFR 4 website and application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
  The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

  These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

  Typeform (TYPEFORM S.L)

  Typeform is a form builder and data collection platform provided by TYPEFORM S.L.

  Personal Data processed: Data communicated while using the service; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: Spain – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Managing support and contact requests

  This type of service allows EasyVFR 4 website and application to manage support and contact requests received via email or by other means, such as the contact form.
  The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

  GrooveHQ

  Your e-mail address and further details you send us in your message will be handled and stored by GrooveHQ Support Software. For full overview of the data storage and handling methods used by GrooveHQ we refer to their website https://www.groovehq.com/our/privacy

• Platform services and hosting

  These services have the purpose of hosting and running key components of EasyVFR 4 website and application, therefore allowing the provision of EasyVFR 4 website and application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
  Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Apple App Store (Apple Inc.)

  EasyVFR 4 website and application is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

  By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of EasyVFR 4 website and application. Much of this information is processed on an opt-in basis.

  Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  Google Play Store (Google Ireland Limited)

  EasyVFR 4 website and application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.

  By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

  Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

  Personal Data processed: Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Registration and authentication provided directly by EasyVFR 4 website and application

  By registering or authenticating, Users allow EasyVFR 4 website and application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

  Direct registration (EasyVFR 4 website and application)

  The User registers by filling out the registration form and providing the Personal Data directly to EasyVFR 4 website and application.

  Personal Data processed: address; billing address; city; company name; country; email address; first name; house number; language; last name; password; picture; profile picture; Tracker; Usage Data; User ID; username; VAT Number; ZIP/Postal code.

  Category of personal information collected according to CCPA: identifiers; commercial information; internet information; sensorial information; inferred information.

• Remarketing and behavioral targeting

  This type of service allows EasyVFR 4 website and application and its partners to inform, optimize and serve advertising based on past use of EasyVFR 4 website and application by the User.
  This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

  Remarketing with Google Analytics (Google Ireland Limited)

  Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Remarketing (Facebook Ireland Ltd)

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of EasyVFR 4 website and application with the Facebook advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Custom Audience (Facebook Ireland Ltd)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of EasyVFR 4 website and application with the Facebook advertising network.

  Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

  Personal Data processed: email address; Tracker.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Ad Manager Audience Extension (Google Ireland Limited)

  Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of EasyVFR 4 website and application and allows selected advertising partners to display targeted ads across the web to them.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Ads Remarketing (Google Ireland Limited)

  Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of EasyVFR 4 website and application with the Google Ads advertising network and the DoubleClick Cookie.

  Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Selling goods and services online

  EasyVFR4.aero Webshop

  We collect information about you during the checkout process on our store.
  
  
  What we collect and store
  
  While you visit our site, we’ll track:
  - Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
  - Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping
  - Shipping address: we’ll ask you to enter this so we can, for instance, estimate shipping before you place an order, and send you the order!
  
  We’ll also use cookies to keep track of cart contents while you’re browsing our site.
  
  When you purchase from us, we’ll ask you to provide information including your name, billing address, shipping address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:
  
  Send you information about your account and order
  - Respond to your requests, including refunds and complaints
  - Process payments and prevent fraud
  - Set up your account for our store
  - Comply with any legal obligations we have, such as calculating taxes
  - Improve our store offerings
  - Send you marketing messages, if you choose to receive them
  
  If you create an account, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.
  
  We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for XXX years for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.
  
  We will also store comments or reviews if you choose to leave them.
  
  
  Who on our team has access
  
  Members of our team have access to the information you provide us. For example, both Administrators and Shop Managers can access:
  - Order information like what was purchased, when it was purchased and where it should be sent, and
  - Customer information like your name, email address, and billing and shipping information.
  
  Our team members have access to this information to help fulfil orders, process refunds and support you.

• SPAM protection

  This type of service analyzes the traffic of EasyVFR 4 website and application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Akismet (Aut O’Mattic A8C Ireland Ltd.)

  Akismet is a SPAM protection service provided by Aut O’Mattic A8C Ireland Ltd.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  Google reCAPTCHA (Google Ireland Limited)

  Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on EasyVFR 4 website and application in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google Ireland Limited)

  Google Tag Manager is a tag management service provided by Google Ireland Limited.

  Personal Data processed: Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Traffic optimization and distribution

  This type of service allows EasyVFR 4 website and application to distribute their content using servers located across different countries and to optimize their performance.
  Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between EasyVFR 4 website and application and the User's browser.
  Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

  Cloudflare (Cloudflare Inc.)

  Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
  The way Cloudflare is integrated means that it filters all the traffic through EasyVFR 4 website and application, i.e., communication between EasyVFR 4 website and application and the User's browser, while also allowing analytical data from EasyVFR 4 website and application to be collected.

  Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Further information about Personal Data

• Google Maps Privacy Policy

  EasyVFR is using the Google Maps API(s), their Google Privacy Policy can be reviewed Google Privacy Policy

• Unique device identification

  EasyVFR 4 website and application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by EasyVFR 4 website and application depends on the payment system used.

• localStorage

  localStorage allows EasyVFR 4 website and application to store and access data right in the User's browser with no expiration date.

• Preference Cookies

  Preference Cookies store the User preferences detected on EasyVFR 4 website and application in the local domain such as, for example, their timezone and region.

• Personal Data collected through sources other than the User

  The Owner of EasyVFR 4 website and application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
  Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

• sessionStorage

  sessionStorage allows EasyVFR 4 website and application to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).

• User identification via a universally unique identifier (UUID)

  EasyVFR 4 website and application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

EasyVFR 4 website and application uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of EasyVFR 4 website and application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, EasyVFR 4 website and application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, EasyVFR 4 website and application and any third-party services may collect files that record interaction with EasyVFR 4 website and application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

EasyVFR 4 website and application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within EasyVFR 4 website and application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running EasyVFR 4 website and application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information, internet information, geolocation data, sensorial information and inferred information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use EasyVFR 4 website and application.

For example, you directly provide your personal information when you submit requests via any forms on EasyVFR 4 website and application. You also provide personal information indirectly when you navigate EasyVFR 4 website and application, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of EasyVFR 4 website and application and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by EasyVFR 4 website and application, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of EasyVFR 4 website and application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

• the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on EasyVFR 4 website and application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.