Privacy Policy - OpenSky

Effective Date: September 25, 2020

Our Privacy Policy explains:

What information we collect and how.
Why we collect it.
How we store, use and share that information.
The choices we offer, including how to access and update information.
How to make an inquiry or complaint if you have concerns about your privacy.

This Privacy Policy applies to information Wing Aviation LLC and its subsidiaries (“Wing”) collect in connection with our mobile and website applications that provide air space-related information, unmanned traffic planning services and other services in connection with the operation of unmanned aircraft systems (“UAS”) or “drones” (“UAS”) (collectively, “OpenSky Services”). Wing looks forward to providing OpenSky Services globally and this Privacy Policy applies to our users in all of our locations.

Some OpenSky Services are provided in collaboration or coordination with third parties, including without limitation, drone registration, licensing, flight authorization, remote identification, drone traffic planning and options to purchase certain related products and services (“Multiparty Services”). Service providers of Multiparty Services include aviation or other government authorities, as well as other companies. This Privacy Policy also applies in circumstances where Wing collects your information through Multiparty Services, even if we have received your information from another service provider.

We may supply a different privacy policy in relation to some of our other services, and that policy will apply to any information provided to or collected by us pursuant to those services.
A Google Account may be required to use some of Wing’s OpenSky Services. Where a Google Account is required, Wing’s use of the information will be governed by this Privacy Policy.

Information we collect.

We collect information in the following ways:

Information in Your Google Account: If you choose to login to OpenSky Services with your Google Account, we will have access to limited profile data, such as the email address and name that is associated with your Google Account.
Information about the User: Information you provide about your pilot or organizational license information such as issue and expiration date and license number.
Information about Your Drone & Flights: If you choose to connect your drone to a device while you are using OpenSky Services, we may collect information about your drone, such as your drone’s serial number and model information. We may associate this information with your Wing OpenSky account. We may also collect information about the flight destination you selected, the flight plan generated, your drone’s location, and information about your past flights, i.e., logbook information.
Information We Collect Automatically When You Use the OpenSky Services: When you access or use OpenSky Services, we may automatically collect certain information, including:
- Device information (e.g. phone, laptop): We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Wing OpenSky account.
- Log information: When you use OpenSky Services, we will automatically collect and store certain information in server logs. Some information, such as your internet protocol address and certain details as to how you used OpenSky Services, will be collected even if you are not logged in. Other information, such as order information or flight-related information, will be collected after you log into OpenSky Services. This includes:
  - Details of how you used OpenSky Services,
  - Internet protocol addresses,
  - Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, and
  - Cookies that may uniquely identify your browser or your Wing OpenSky account.
Location Information: When you use OpenSky Services, we may collect and process information about your actual location through your device (e.g., phone, laptop). We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers. However, if you use OpenSky Services but are not logged in, we will not store your location information.
Unique Application Numbers: Certain OpenSky Services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Wing when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
Information You Provide to Us: We collect information you provide directly to us. For example, we collect information when you participate in any interactive features of the OpenSky Services, fill out a form, provide feedback, participate in a contest or promotion, communicate with us via third party sites, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, UAS licensing and registration information, information related to the drone you are operating and your proposed flight destination, delivery information and any other information you choose to provide.
Google Analytics: Wing’s website and apps use Google Analytics to understand how visitors engage with our site and apps. If you don’t want Analytics to be used in your browser, you can install the Google Analytics browser add-on. Learn more about Google Analytics and privacy.
Cookies and Similar Technologies: We and our partners use various technologies to collect and store information when you use OpenSky Services or visit our website, and this may include using cookies or similar technologies to identify your browser or device.
Information We Collect From Other Sources: We may also obtain information from other sources, third parties, or publicly available data and combine that with the information we collect through OpenSky Services. For example, we may collect information about you from non-Wing service providers involved in Multiparty Services and their users, or if you engage with our third party social media channels,. Information we obtain about you from these other sources may be associated with your Wing OpenSky account. When information is associated with your Wing OpenSky account or otherwise personally identifies you, we treat it as personal information.

Payment information

If OpenSky Services or Multiparty Services require payment, you may need to provide your credit card information directly to our third party payment processor, or through a third party’s website to which OpenSky Services links. This information will be governed by the terms of the payment processor’s privacy policy or such third party site. Wing does not have access to credit card information provided to any such third party payment processor.

How we use the information we collect.

Wing may use your data in the following ways:

We use the information we collect to provide, maintain, protect, promote and improve our OpenSky Services, to develop new ones, and to protect Wing and our users. We may use the information we collect to help us solve any issues you might be facing with the OpenSky Services.
We may use the information we collect to inform you about our OpenSky Services, for example, letting you know about upcoming changes, or improvements, or if you have opted in for marketing purposes.
We use information collected to improve your user experience and the overall quality and safety of our OpenSky Services, and to inform the development of new features or OpenSky Services.
Enable Multiparty Services, including portions of Multiparty Services that are not provided by Wing, but by other service providers.
Monitor and analyze trends, usage, and activities in connection with OpenSky Services.
Comply with any applicable law, regulation, legal process or enforceable governmental request.
Enforce applicable terms of service, including investigation of potential violations.
Detect, investigate, prevent, or otherwise address fraud, security or technical issues.
Protect against harm to the rights, property or safety of Wing, our users or the public as required or permitted by law.
We will ask for your consent before using the information for a purpose other than those related to the purposes set out in this Privacy Policy.

Accessing and updating your personal information.

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how you interact with OpenSky Services.

Whenever you use OpenSky Services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly. In some circumstances you may alternatively be able to delete it – unless we have to keep that information for legitimate business or legal purposes. For example, we may in the future be required by government authorities to retain certain information regarding your flight activity.
We aim to maintain OpenSky Services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our OpenSky Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

You may request access to the information we hold about you or request correction of that information by sending a written request to wing-privacy@wing.com.

Information we share.

We do not share personal information with companies, organizations and individuals unless one of the following circumstances applies:

With your consent: We will share personal information with companies, organizations or individuals outside of Wing when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information, as defined by the General Data Protection Regulation 2016/679, where required by law.
To related companies in our group: Wing may share personal information with its affiliates (other companies in our group of companies).
For external processing: We provide personal information to our affiliates or other trusted businesses or persons to process it for us based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
With Aviation Authorities: When you use OpenSky Services to register your drone, apply for a license or request access to controlled airspace from an aviation or other government authority, we share your information with that government authority. This includes without limitation your personal information, information about your drone, your proposed flight destination and the flight plan that OpenSky Services may generate for you.
For Multiparty Services: Certain OpenSky Services require that Wing share personal information with third parties providing or enabling similar services. For example, in areas where multiple service providers of unmanned traffic planning services are permitted, we and other service providers will share information about your proposed flight in order to detect conflicts.
For Remote Identification Services: In some jurisdictions, government authorities may require that your drone and operator information be provided for remote identification purposes. In these jurisdictions, we will share your information with the applicable government authority or agency or provider authorized by the government authority, such as other remote identification service providers. This information could include your name, contact information (including address and telephone number) license information, drone serial number and other aircraft identifiers, your user ID and details of your flight (e.g., location, time and speed).
For legal reasons: We will share personal information with companies, organizations or individuals outside of Wing if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Comply with any applicable law, regulation, legal process or enforceable governmental request.
- Enforce applicable terms of service, including investigation of potential violations.
- Detect, prevent, or otherwise address fraud, security or technical issues.
- Protect against harm to the rights, property or safety of Wing, our users or the public as required or permitted by law.
- Obtain legal advice.

In some cases, the organizations that we share your information with or that process your information with may be based outside of the country where you live. For example, we may share your information with third parties in the United States.

We may share non-personally identifiable information publicly and with other parties. For example, we may share this information publicly to show trends about the general use of OpenSky Services.

We may share your personal information in connection with a merger, acquisition, or sale of Wing’s assets. We will take reasonable steps to ensure that your personal information continues to be subject to the same protections set out in this Privacy Policy. Information storage and security.

We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage and application data caches.

Wing also stores personal information on our servers in many countries around the world, including the United States. We may therefore store and process your personal information on servers outside the country where you live. Data protection laws vary among countries. We work hard to protect Wing and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

We encrypt many of our services, including protecting all user data in transit by using TLS to encrypt access to our services.
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
We restrict access to personal information to Wing employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

When this Privacy Policy applies.

Our Privacy Policy applies to information collected by Wing in relation to OpenSky Services, and the other circumstances described above in “Information we collect.” This Privacy Policy also applies in circumstances where Wing collects your information through Multiparty Services, even if we have received your information from another service provider. Except for the circumstances that we have described in this Privacy Policy, our Privacy Policy does not apply to services or products offered by other companies, other service providers, or individuals, including companies you may transact with through our services.

Compliance, complaints and cooperation with regulatory authorities.

We regularly review our Privacy Policy, and our compliance with privacy requirements. We also adhere to several self-regulatory frameworks.

If you wish to make a complaint about how we have handled your personal information, you may do so by writing to wing-privacy@wing.com. When we receive written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly. You can also contact your local data protection authority if you have concerns regarding your rights under local law.

Retention and deletion.

We retain personal information for as long as necessary for legitimate business or legal purposes. Sometimes business or legal requirements oblige us to retain certain information for extended periods of time. Reasons we might retain some data for longer periods of time include:

Security, safety, fraud and abuse prevention, detection and resolution
Financial records keeping
Complying with legal or regulatory requirements
Ensuring continuity and safety of our OpenSky and Multiparty Services
If you communicate directly with Wing

We try to ensure that our OpenSky Services protect information from accidental or malicious deletion. Because of this, there may be delays between when you delete something and when copies are deleted from our active and backup systems. You can submit a deletion request by contacting wing-privacy@wing.com.

We also keep information which will help us improve our OpenSky Services, and conduct further research and product development. Wherever possible, we avoid retaining personal information for this purpose.

Changes to this privacy policy. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy on a regular basis, including without limitation whenever you access OpenSky Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Contacting us. If you have any questions about this Privacy Policy, any requests concerning your personal information, or would like to make a complaint, please contact us at wing-privacy@wing.com.