Welcome to our Privacy Policy. We provide a cloud-based software service that allows users to upload flight logs and data pertaining to the flight, including imagery and video, of UAVs (drones) for analysis and reporting. We also provide an online community forum for users to share and discuss flights and their equipment, as well as a drone forecast service.

This Privacy Policy explains how we may collect, use, disclose, and secure information we obtain through the "Service." The terms "AirData," "we," "us," and "our" include Airdata UAV, Inc., Healthydrones.com, OKtoFLY.com and our affiliates and subsidiaries. This Privacy Policy is incorporated by reference into our Terms of Service. Any capitalized terms used and not defined in this Privacy Policy shall have the meaning given to them in the Terms of Service.

Unless otherwise specified, we are the data controller with respect to information processed pursuant to this Privacy Policy.

This Privacy Policy applies to:

• Visitors to our websites (including airdata.com, healthydrones.com, OKtoFLY.com, and related domains);
• Users of our Service, whether through the websites or mobile applications;
• Prospective customers who contact us;
• Customers, authorized users, and resellers; and
• Marketing and sales communications.

Information processed under a customer agreement or Data Processing Addendum ("DPA") is governed by that agreement, not this Privacy Policy.

The Service Collects Your Information

We may collect information from you as follows:

Registration and Account Information. You must register to use the Service. To register, you may need to provide information about yourself, such as your name, email address, address, and telephone number. You may also provide other optional information.

Connected Flight Apps and UAV Data. When you connect other flight app accounts or upload UAV data to your Service profile, we collect information from such apps and data files. Such information may include photographs and videos taken by the UAVs.

LAANC Data. We may collect Low Altitude Authorization and Notification Capability data ("LAANC Data") from drone operations, such as name, phone number, email address, location and flight boundaries, submission reference code, safety justification for non-authorized operation, operator certification information, and aircraft registration number used to obtain an authorization from the Federal Aviation Administration ("FAA"). For more information regarding our collection of LAANC Data, view our LAANC Data Processing Addendum located beneath this Privacy Policy.

Making Payments. When you make payments through the Service, you may need to provide financial account information, such as your credit card number, to our third-party service providers, including Stripe. We do not collect or store such information, though we may receive information about completed transactions that does not include credit card or bank account numbers.

Communicate with Us. We may collect information about you through your communications with our customer-support team or through other communications with us, including through social media.

Information and Content from Your Device. The Service automatically collects information about your device, such as a device ID, location and browser type, so that we can provide and customize functionality, such as push notifications. With your permission, the Service may access and collect information from your device's contact list and photo storage.

Sensitive Data. We do not typically collect the type of data viewed as "sensitive" from you, such as information required to provide health-care services or process payroll, gender or racial information, or other sensitive personal information. The provision of this type of information will be voluntary, unless it is required by law. If we collect sensitive information, we will ask you to provide your consent to collect, store, and, as applicable, transfer this data to third parties. We take all reasonable security measures to protect the confidentiality and integrity of sensitive data collected, stored, and used.

Automatic Data Collection: Cookies and Related Technologies. When you visit our Service or open our emails, we and our third-party partners, such as advertising networks, social media widgets, and analytics providers, may collect certain information by automated means, such as cookies, web beacons and web server logs. By using the Service, you consent to the placement of cookies, beacons, and other similar technology in your browser and on emails in accordance with this Privacy Policy. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, geographical coordinates, and information about the usage of our Service. We may use this information, for example, to determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. We may link this data to your profile.

Our partners also may collect information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same partners. When they provide such services, they are governed by their own privacy policies. We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit www.google.com/policies/privacy/partners/.

You may be able to change browser settings to block and delete cookies when you access the Service through a web browser. However, if you do that, the Service may not work properly. The Service does not respond to browser do-not-track signals.

By using the Service, you are authorizing us to gather, process, analyze, and retain data related to the provision of the Service.

How AirData Uses Your Information

Internal and Service-Related Usage. We use information for internal and service-related purposes. We may use and retain any data we collect to provide and improve any of our services.

Communications. We may send emails to the email address you provide to us and push notifications to your mobile device if you have downloaded our app and enabled notifications, to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, and other Service-related purposes. We may also send you the text messages you request through the Service, such as alert messages.

Marketing. We may use information to provide online advertising on the Service and to send you information we think may be useful or relevant to you. You may opt out of email marketing by using the unsubscribe link in a marketing email.

Aggregate Data. We may anonymize or aggregate data collected through the Service and use and disclose it for any purpose.

Compliance. We may use information for compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

Other Uses. We may use information for other purposes for which we provide specific notice at the time the information is collected.

Legal Bases for Processing (GDPR)

Where GDPR applies, AirData processes Personal Data on the following legal bases:

• Contractual necessity – to provide the Service;
• Legitimate interests – including security, product improvement, marketing, and business operations;
• Consent – where required by law (e.g., certain marketing communications); and
• Legal obligation – compliance with applicable laws and regulations.

You may withdraw consent at any time where consent is the legal basis.

How we share the information we collect

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers we use to help us provide and improve the Service. For example, we will provide information to service providers that provide web and database hosting services, and may provide geo-location information to third-party map or navigation service providers. We use the Google Maps service, and you agree to the Google privacy policy located at http://www.google.com/policies/privacy.

You May Share Data with Others. You may share the information and content you submit to the Service. For example, you may participate in discussions on the Service and share your name, photo, other profile information, and flight information with other users. You may also use the Service to create a link to a particular data set you have chosen that will permit others who use that link to see the data set, for example when you share a flight using our Sharing feature. We are not responsible for how others will view and use the posted information.

FAA. We may share LAANC Data with the FAA. For more information regarding the FAA's use of LAANC Data, you may visit the FAA’s “Privacy Statement Regarding LAANC and USS Providers Collection of Information” located here. See the LAANC Data Processing Notice Addendum, below, for additional information.

Marketing. We do not rent, sell, or share personal information about you that we collect on the Service with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission. We may allow access to data collected by the Service to enable the delivery of online advertising to you and others on the Service, or to send you information we think may be useful or relevant to you.

Legal and Similar Disclosures. We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; or protect your, our, or others' rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

With Your Permission. We may also disclose information about you with your permission.

Your Choices

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Additional Rights. In addition, depending on your location, you may have the right to:

• Access your information;
• Correct inaccurate data;
• Delete your information;
• Restrict or object to processing;
• Obtain your information (data portability);
• Withdraw consent for processing; and
• Lodge a complaint with a supervisory authority.

Requests may be submitted to legal@airdata.com.

Information Security

We maintain reasonable administrative, technical, and organizational safeguards designed to protect your information against unauthorized access, disclosure, alteration, or destruction. No system is 100% secure, and we cannot guarantee absolute security.

By using the Service or providing your information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service.

Third Parties

Our Service may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Children's Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at legal@airdata.com. If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the child's account.

International Users

Our Service is hosted in the United States and intended for visitors located within the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing your information on or to the Service, you consent to such transfer, storage, and processing.

Where required by law, we implement appropriate safeguards, including Standard Contractual Clauses or other lawful transfer mechanisms. See the section below for specific provisions relating to our compliance with the Data Privacy Framework ("DPF").

Transfers from EU, UK, and Switzerland; Data Privacy Framework

We comply with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the US Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

We commit to resolving applicable complaints about our collection or use of your personal information in accordance with the DPF Principles. EU individuals with inquiries or complaints regarding our policy or data privacy actions should first contact us as indicated in the "Contact Information" section below.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to our use of your data. Under certain conditions, you may have the right to invoke binding arbitration regarding your privacy rights.

We have further committed to refer unresolved privacy complaints under the EU-U.S. DPF Principles to an independent U.S.-based third-party dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, JAMS (free of charge) at https://www.jamsadr.com/DPF-Dispute-Resolution. To file a DPF claim with JAMS, go to https://www.jamsadr.com/file-a-dpf-claim.

We are liable for the processing of personal information we receive under the DPF Principles and subsequently transfer to a third party acting as an agent on our behalf. We will remain liable under the DPF Principles if our agent processes such personal information in a manner inconsistent with the DPF Principles, unless we prove that we are not responsible for the event giving rise to the damage.

The Data Privacy Framework Principles include (in summary form):

• Notice – of how we collect and use personal data;
• Choice – of whether and under what conditions personal information may be disclosed to third parties;
• Accountability for onward transfer – taking responsibility for onward transfers of personal information;
• Security – taking reasonable and appropriate measures to avoid loss, misuse, or unauthorized access to, or disclosure of, personal information;
• Data integrity and purpose limitation – processing personal information only for specified purposes;
• Access – providing access and opportunity to correct personal information we hold; and
• Recourse, enforcement and liability – maintaining access to independent recourse and enforcement mechanisms for addressing problems.

If you have a question or complaint related to our participation in the Data Privacy Framework, we encourage you to contact us. For any complaints related to the Data Privacy Framework that we cannot resolve directly, we have chosen to cooperate with the relevant EU, UK, or Swiss Data Protection Authorities, as applicable. As described above, binding arbitration is available to address residual complaints not resolved by other means.

Update Your Information or Pose a Question or Suggestion

If you would like to request that we update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, please send an email to legal@airdata.com.

Changes to Our Privacy Policy and Practices

We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If we materially change the way in which we use or share personal information previously collected from you through the Service, we will notify you through the Service, by email, or other communication.

Contact Information

If you have any questions, comments, or concerns about our processing activities, please reach us at:

Airdata UAV, Inc.4364 Town Center Blvd., STE 207El Dorado Hills, CA 95762info@airdata.com

LAANC Data Processing Notice Addendum

This Data Processing Notice Addendum (the "Addendum") for Low Altitude Authorization Notification Capability Data ("LAANC Data") supplements the information contained in our Privacy Policy and applies solely to all users who utilize AirData's Services for LAANC authorizations. Any capitalized terms not defined here will have the meaning set forth in the Privacy Policy. Beyond this Addendum, the Service is subject to our Terms of Service.

We adopt this Addendum to comply with the FAA's requirements to provide LAANC services to you, whereby AirData, a USS (UAS Service Supplier), is required to collect LAANC Data and share it with the FAA in order to process your request for a LAANC authorization and for the FAA to ensure the safety of the National Airspace System.

USS Statement

AirData is a provider of UAS services within the FAA's LAANC. LAANC may be used to satisfy compliance with Air Traffic authorization. Information provided is based on real-time and available projected information on airspace status and airport-specific maps, and that information is subject to change. Planning tools should be checked prior to flight for any changes that could impact the operation.

LAANC Data That We Collect

For LAANC purposes, AirData may collect LAANC Data such as:

• Your name and phone number
• Email address
• Your location
• The planned flight area and flight boundaries
• Submission reference code, and status of those codes
• Safety justifications for non-auto-authorized operations
• Operator certificate information and aircraft registration number

Data Retention

We store the personal information and LAANC Data we receive as described here for as long as you use our Service or as necessary to fulfill the purpose(s) for which it was collected, provide our Service, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

How We Use LAANC Data

We may process your LAANC Data in compliance with federal law, the LAANC Memorandum of Agreement, and LAANC Performance Rules.

Please review our Privacy Policy for further details on how we may use your data.

How We Share the LAANC Data

When you use the LAANC services, we may share LAANC Data with the FAA, pursuant to law, federal regulation, the LAANC Memorandum of Agreement, and the LAANC Performance Rules.

Please review our Privacy Policy for further details on how we may disclose your data to other third parties.

Your Choices

You have the right to access, request a copy, or request deletion of your LAANC Data collected by AirData by emailing us at support@airdata.com. We will process such requests in accordance with applicable laws. To protect your privacy, AirData will take steps to verify your identity before fulfilling your request.

Ownership; Proprietary Rights

Intellectual property rights claimed in LAANC Data created by a UAS-operator or derived from UAS-operator-created LAANC Data is subject to the provisions in our Terms of Service.

Security

We have put in place appropriate security measures to protect LAANC Data in accordance with the Information Security section of our Privacy Policy.