MY SKPAD.ME PRIVACY POLICY by FORFLYAWAY - July 2020
This privacy policy (hereinafter referred to as the "Privacy Policy") defines the legal framework for the collection, use and processing by the Company of the personal data of users browsing and / or making use of the services offered or offering their services via the web platform developed by Forflyaway (hereinafter referred to as the "Users") also hosting the payment area for advertiser formulas of the mySKpad.me mobile application accessible at the address www.forflyaway.co designed and operated by the Company (hereinafter referred to as the "Platform").
The provision of personal data collected under this Privacy Policy is mandatory. This information is necessary for the processing and for the provision of the services offered by the Company via the Platform (hereinafter referred to as the “Services”). The lack of information prevents the proper functioning of the Services offered online.
The Company undertakes to comply with the applicable regulations on the protection of personal data (hereinafter referred to as “Personal Data”), and in particular the obligations arising from European regulation No. 2016/679 on the protection of personal data (RGPD ).
The Company collects personal data only in compliance with the terms of this Privacy Policy and any legal and reasonable instructions given by the User at any time.
When the Company finds a violation of rights in the context of the processing of personal data, this violation will be notified to the CNIL within a period not exceeding seventy-two (72) hours after becoming aware of it.
Any violation relating to the processing of the User's personal data will be notified to the User concerned by e-mail, within one (1) month.
ARTICLE 1: INFORMATION COLLECTED
1.1 Throughout the duration of the use of the Platform and the Services, the Company may collect any information, directly or indirectly identifying the User, necessary for the creation of an account on the Platform and necessary for the proper functioning of the Platform (hereinafter referred to as “Personal Data”).
During his first connection, the User expressly consents to the processing of his Personal Data within the limit of processing strictly necessary for the proper functioning of the Platform.
The provision of personal information collected is mandatory. This information is necessary for the processing and for the provision of the Services. The lack of information prevents the proper functioning of the Services offered online.
This concerns in particular:
Personal Data relating to the identity of the User and in particular their title, surname, first name, email address, telephone number, address and postal code;
Personal Data relating to the use of the aircraft by the User: parent flying club, piloting license, aircraft used, favorite aerodromes, travel plans, personal presentation and comments published on the Platform by the User;
Personal Data relating to browsing, collected automatically by the Company and in particular the anonymized IP address, the browser used, the browsing time, the operating system used, the language and the pages viewed;
Data relating to the statistics of visits to the Platform by Users and in particular traffic data and other data or communication resources that the User uses when accessing the Platform;
1.2 Personal Data can be collected directly when the User communicates them to the Company by means of the User account creation forms.
requesting contact, subscribing to the newsletter available on the Platform and reporting illegal content.
The Company grants itself the right to review, browse or analyze the communications exchanged between the Company and the Users, between the Users via the Platform for the purposes of fraud prevention, risk assessment, compliance with regulations, survey, product development, research and user support.
The provision of Personal Data collected for these purposes is mandatory and strictly necessary for the proper functioning of the Platform. Otherwise, the Services cannot be provided.
ARTICLE 2: USE OF PERSONAL DATA COLLECTED
The Company uses, stores and processes Personal Data, in order to feed, understand, improve and develop the Platform, to create and maintain an environment of trust with Users as well as to comply with the legal obligations incumbent on it and in particular in order to:
2.1 Development of the Platform
Allow Users to access / use the Platform;
Allow Users to communicate with Company staff;
Allow Users to communicate with each other;
Manage, protect, improve and optimize the Platform through statistics, analyzes and studies;
Provide customer service tailored to the needs of Users;
Send Users messages of assistance or relating to the Services, updates, security alerts and notifications;
As part of the conduct of fraud detection and prevention actions;
2.2 Creation and maintenance of an environment of trust for Users
Detect and prevent fraud, spam, abuse, security incidents and other harmful activities;
Conduct safety investigations and risk assessments;
Check or authenticate the information or identifications transmitted by Users;
Respect the legal obligations incumbent on the Company;
Resolve any disputes with Users;
2.3 Provide, Customize, Evaluate and Improve our Advertising and Marketing of Services
Send promotional messages, commercial and advertising information;
Personalize, evaluate and improve the advertising of the Services;
ARTICLE 3: SHARING AND DISCLOSURE OF PERSONAL DATA
3.1 The Company may disclose Users' Personal Data to courts, government or law enforcement authorities, or authorized third parties, if the law requires or permits, or if such disclosure is reasonably deemed necessary: (i) to comply with the legal obligations of the Company, (ii) in order to comply with the legal process and to respond to claims brought against the Company, (iii) to respond to requests verified as part of a judicial investigation or any alleged or suspected illegal activity or any other activity which may expose the Company, the User to legal liability.
3.2 The Company has the option of subcontracting all or part of the performance of the Services in compliance with the legal provisions in force.
The Company may also subcontract the hosting services for Personal Data on the condition that the Personal Data is processed by a hosting platform located exclusively on the territory of the European Union.
The subcontractor will be authorized to process on behalf of the Company the Personal Data necessary to provide the Services.
3.3 Personal Data may be transmitted to technical service providers, for the sole purpose of the proper performance of the Services, or to its various suppliers such as payment solution providers.
ARTICLE 4: PROTECTION OF PERSONAL DATA - USERS 'RIGHTS
4.1 The Personal Data communicated by the User will be destroyed at the latest six (6) months after the end of the use of the Services by the User. The Company reserves the right to retain certain data in order to justify, where applicable, the perfect performance of its contractual or legal obligations. The data thus stored will be limited to what is strictly necessary.
4.2 In all cases, Users benefit from a right of access, rectification, modification, opposition, portability and deletion of Personal Data concerning them by writing to the following address:
hello@forflyaway.co indicating his name, first name, e-mail and address.
In accordance with the regulations in force, all requests must be signed and accompanied by a photocopy of an identity document bearing the User's signature.
In accordance with Article 48 of European Regulation No. 2016/679 on data protection, the Company has not appointed a Personal Data Protection Officer (DPO).
The User can recover his Personal Data in an open and readable format. The right to portability is limited to the data provided by the User concerned. It applies on the basis of the prior consent of the User. The Company undertakes to transfer, on request, within one (1) month, any document collecting Personal Data to the User in order to be able to implement the right to portability. The costs related to data recovery are the responsibility of the User by making the request.
ARTICLE 5: USE OF COOKIES
In accordance with CNIL deliberation n ° 2013-378 of December 5, 2013, the Company informs, moreover, that cookies record certain information which is stored in the memory of the hard disk of the User. This information is used to generate audience statistics.
An alert message, in the form of a banner, asks the User beforehand if he wishes to accept cookies.
Users going to the home page or another page of the Platform directly from a search engine will be informed:
the precise purposes of the cookies used;
the possibility of opposing these cookies and of changing the parameters by clicking on a link in the banner;
and the fact that the continuation of its navigation constitutes agreement to the deposit of cookies on its terminal.
To guarantee the free, informed and unequivocal consent of Users on the Platform, the banner will not disappear until it has continued to browse.
Without prior consent, cookies will not be placed and read.
ARTICLE 6. NEWSLETTER
Depending on the choices made by the User, he may be the recipient of the newsletter.
By checking the box provided for this purpose or by expressly giving their consent to this end, the User accepts that the Company can send them a newsletter (information letter) that may contain information relating to new activities offered by the Partners of the society.
Users will have the option to unsubscribe from the newsletter by clicking on the link provided for this purpose, present in each of the newsletters (information letters).