Privacy Policy

Effective Date: April 30, 2020

1. Who We Are

FlyEasy is an online digital platform that provides Users the ability to search and inquire on charter aircraft availability worldwide, send and manage automated email campaigns, provide trip quote estimates and promote charter aircraft availability on their website, manage charter aircraft fleet and flight inventory, provide charter flight quoting, scheduling, and invoicing, collect payments for charter trips, access data analytics, and other related services (the “Services”). FlyEasy’s platform is provided through a Software as a Service (SaaS) model and operated by FlyEasy Corp, a company headquartered in the Province of Ontario in Canada ("we," "us," "our," and "FlyEasy"). At FlyEasy the privacy and security of our Users and Visitors are of paramount importance. FlyEasy is committed to protecting the data you share with us.

2. Key Terms

In this Privacy Policy, these terms have the following meanings:

“Person(s)” means any individual person, natural person, sole proprietorship, partnership, corporation/company, trust, joint venture, any governmental authority or any incorporated or unincorporated entity or association of any nature, and any other type of legal entity.

"Personal Information" means any and all personal information within the meaning or as construed for the purpose of the Personal Information Protection and Electronic Documents Act (PIPEDA) including, without limitation, any and all information that identifies or may identify any User, User’s Client or Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, phone number, gender, occupation, or other demographic information.

“Privacy Policy” means this policy of FlyEasy which describes the collection, use, storage, sharing and protection of your Personal Information.

"Subscriber List" is a list of User’s Clients a User may upload or manage on our platform and all associated information related to such User’s Clients (for example, email addresses).

"User" or “Users” or “You” means any Person that is registered with us to use the Services.

"User’s Client(s)”or “Client(s)”means any Person that may contact our Users or that may be contacted by such Users through our Services. In other words, a User’s Client is anyone on a User’s Subscriber List or about whom a User has given us information. For example, if you are a User, a subscriber to your email marketing campaigns would be considered a User’s Client.

"Website(s)" means any website(s) we own and operate (such as www.flyeasy.co) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this Privacy Policy.

"Visitor(s)" means any Person who visits any of our Websites, including Users.

"you" and "your" means, depending on the context, either a User, a User’s Client, or a Visitor.

3. Types of Data We Collect

Website Cookies
Like most websites, our Websites use cookies to collect information. Cookies are small data files which are placed on your computer or other devices (such as smartphones or tablets) as you browse our Websites. They are used to remember when your computer or device accesses our Websites. Cookies are essential for the effective operation of our Websites and to help you submit inquiries online. They are also used to tailor the products and services offered and advertised to you, both on our Websites and elsewhere. The information we collect includes information about browsing and inquiry behaviour by Visitors, which includes information about pages viewed, inquiries sent and the Visitor journey around our Websites. Furthermore, we collect User information to ensure the effective operation of the Services, which may include the User’s email address, name, company name, and phone number for example. All information collected via cookies is encrypted and protected against modification.

Google Analytics
When someone visits our Website(s) we use a third-party services providers such as Google Analytics, Lucky Orange, Zendesk, Facebook and LinkedIn, to collect standard internet log information and details of Visitor behaviour patterns. We do this to find out things such as the number of Visitors to the various parts of the Website(s). This information is only processed in a way which does not identify anyone. We do not make, and do not allow any of the third-party services providers to make, any attempt to find out the identities of those visiting our website.

Mailing Lists
As part of the registration process on our Websites, we collect Personal Information. We use that information for a couple of reasons: to tell you about stuff you’ve asked us to tell you about; to contact you if we need to obtain or provide additional information; to check our records are right and to check every now and then that you’re happy and satisfied. We don't rent or trade email lists with other organizations and businesses. We use a third-party provider, Mailchimp to deliver information to you. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our communications. For more information, please see Mailchimp’s privacy policy. You can unsubscribe to general mailings at any time of the day or night by clicking the unsubscribe link at the bottom of any of our emails or by emailing us at info@flyeasy.co.

4. Client Privacy
5. A) Information We Collect

The Personal Information that we may collect broadly falls into the following categories:

(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Clients. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your CRM account with FlyEasy), or communicate with us in any other way.

We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Subscription Agreement and in this Privacy Policy.

This information may include:

• Registration information: You need a FlyEasy account to use the Services as a User. When you register for an account, you will be asked to provide certain basic information, such as your name, email, password, company name, address, and phone number.
• Billing and communications information: If you purchase our Services, you may also need to provide us with payment and billing information, such as your credit card details and billing address. FlyEasy will also maintain a record of your billing transactions and purchases, and any communications and responses.
• Information we process on behalf of our Users: In order to distribute flight inventory via email or use certain features in your account, you need to upload a Subscriber List that provides us information about your Clients, such as their names, email addresses and telephone number. We use and process this information to provide the Services in accordance with your instructions.

(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more in Section 3 above.

This information may include:

• Device information: We collect information about the device and applications you use to access the Services, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
• Log data: Our web servers keep log files that record data each time a device accesses those servers and those log files contain data about the nature of each access, including originating IP addresses. We may also access metadata and other information associated with files that you upload into our Services.
• Product usage data: We collect usage data about you whenever you interact with our Services, which may include the dates and times you access the Services and your browsing activities (such as what portions of the Services are used). We also collect information regarding the performance of the Services, including metrics related to the deliverability of emails and other communications you send through the Services. This information allows us to improve the content and operation of the Services, and facilitate research and analysis of the Services.

1. B) Use of Personal Information

We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:

• To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.
• To send you Service alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this Privacy Policy.
• To communicate with you about your account and provide customer support. For example, if you are a user of our Services we may get in touch regarding aircraft fleet updates, pricing, or for training purposes on using our Services.
• To enforce compliance with our Subscription Agreement and applicable law, and to protect the rights and safety of our Users and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations.
• To provide, support and improve the Services. For example, this may include sharing your information with third parties such as aircraft quoting and scheduling systems providers in order to provide and support our Services or to make certain features of the Services available to you.
• For our data analytics projects. We will act as a data controller to process data for our data analytics projects in reliance on our legitimate business interests of improving and enhancing our Services for our Users. As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure. You can opt out of data analytics projects at any time by emailing us at info@flyeasy.co.

1. C) User Subscriber Lists

Subscriber Lists can be created in a number of ways, including importing Clients from a CSV file or adding them manually. Your Subscriber Lists are stored on our secure cloud infrastructure. We do not, under any circumstances, sell your Subscriber Lists. If someone on your Subscriber List submits a complaint or contacts us, we may then contact that Person. You may export (download) your Subscriber List from FlyEasy at any time. If we detect abusive or illegal behavior related to your Subscriber List, we may share your Subscriber List or portions of it with affected ISPs or anti-spam organizations to the extent permitted or required by applicable law.

1. D) Other Data Protection Rights

You and your Clients may have the following data protection rights:

• To access, correct, update or request deletion of Personal Information. FlyEasy takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a User, you can manage many of your individual account and profile settings within the dashboard provided through the FlyEasy platform, or you may contact us directly by emailing us at info@flyeasy.co. You can also manage information about your Clients within the dashboard provided through the FlyEasy platform to assist you with responding to requests to access, correct, update or delete information that you receive from your Clients.
• In addition, individuals who are residents of the European Economic Area can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us at info@flyeasy.co. If any of your Clients wishes to exercise any of these rights, they should contact you directly, or contact us at info@flyeasy.co.
• Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. If you receive these requests from Clients, you can change such Clients’ subscription preferences within the FlyEasy platform to ensure that you only market to Clients who have not opted out of receiving such emails.
• The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.

We respond to all requests we receive from Users wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Clients, we will either direct the Client to reach out to you, or, if appropriate, we may respond directly to their request.

5. Client Privacy
6. A) Information We Collect

The Personal Information that we may collect or receive about you broadly falls into information we receive about Clients from our Users. A User may provide Personal Information about Clients to us through the Services. For example, when a User uploads their Subscriber List, or when a Client signs up for a User’s Subscriber List on a signup form powered by FlyEasy, the User may provide us with their contact information or other Personal Information about Clients such as their name, email address, or telephone number. The Client may have the opportunity to update some of this information by electing to update or manage their preferences via an email they receive from FlyEasy on behalf of the User.

1. B) Legal Basis for Processing

We process Personal Information about you as a data controller, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; ensuring the security of the Services and our Websites.

1. C) Other Data Protection Rights

You may have the following data protection rights:

• To access, correct, update or request deletion of your Personal Information. FlyEasy takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, by emailing us at info@flyeasy.co. We will consider your request in accordance with applicable laws.
• In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at info@flyeasy.co.
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

As described above, for much of the Personal Information we collect and process about Clients through the Services, we act as a processor on behalf of our Users. In such cases, if you are a Client and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by FlyEasy as a processor on behalf of our Users, you should contact the relevant User that is using the Services, and refer to their separate privacy policies.

If you no longer want to be contacted by one of our Users through our Services, please unsubscribe directly from that User’s Subscriber List or contact the User directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the User of your request.

We respond to all requests we receive from Persons wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

6. Your Choices and Opt-Outs

Users and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages. Also, all opt-out requests can be made by contacting info@flyeasy.co. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Users cannot opt out of these messages unless you cancel your FlyEasy subscription and Services or if your FlyEasy subscription is otherwise suspended or terminated.

7. Our Security

We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Privacy page here. If you have any questions about the security of your Personal Information, you may contact us at info@flyeasy.co.

FlyEasy accounts require a username and password to log in. Users must keep their username and password secure, and never disclose it to a third party. Because the information in a User’s FlyEasy account is so sensitive, account passwords are hashed, which means we cannot see a User’s password. We can however provide Users with instructions on how to reset their password.

8. Retention of Data

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:

• Whether we have a legal or contractual need to retain the data.
• Whether the data is necessary to provide our Services.
• Whether our Users have the ability to access and delete the data within their FlyEasy accounts.
• Whether our Users would reasonably expect that we would retain the data until they remove it or until their FlyEasy accounts are closed or terminated.
• When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it.

9. Changes to this Policy

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the date located at the top of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Websites. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this Privacy Policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy that was in effect on each respective date you visited the Websites.