Effective Date: May 24, 2018
FlyEasy and OpenPoint are online digital platforms provided through a Software as a Service (SaaS) model (the "Services") 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 Clients and Visitors are of paramount importance. FlyEasy is committed to protecting the data you share with us.The Services enable our Clients to, among other things, send and manage automated email campaigns, serve automated aircraft quote estimates and aircraft availability data. We also provide other related services such as data analytics, fleet management, flight inventory management, and charter flight quoting & scheduling. Find out more about our Services here.
"Contact" is a person a Client may contact through our Services. In other words, a Contact is anyone on a Client’s Subscriber List or about whom a Client has given us information. For example, if you are a Client, a subscriber to your email marketing campaigns would be considered a Contact.
"Subscriber List" is a list of Contacts a Client may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).
"Client" means any person or entity that is registered with us to use the Services.
"Personal Information" means any information that identifies or can be used to identify a Client, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
"Visitor" means any person who visits any of our Websites.
"you" and "your" means, depending on the context, either a Member, a Contact, or a Visitor.
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 organisations 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 notice. 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 email@example.com.
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 Contacts. 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.
This information may include:
- Registration information: You need a FlyEasy account to use the Services as a Client. 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 Clients: 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 Contacts, such as their names and email addresses. We use and process this information to provide the Services in accordance with your instructions.
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.
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 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 Terms of Service and applicable law, and to protect the rights and safety of our Clients 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 products and services for our Clients. 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 firstname.lastname@example.org.
Subscriber Lists can be created in a number of ways, including importing Contacts 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.
You and your Contacts 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 Client, 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 email@example.com. You can also manage information about your Contacts 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 Contacts.
- 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 firstname.lastname@example.org. If any of your Contacts wishes to exercise any of these rights, they should contact you directly, or contact us at email@example.com.
- 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 Contacts, you can change the Contact subscription preferences within the FlyEasy platform to ensure that you only market to Contacts 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 individuals 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 Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.
The Personal Information that we may collect or receive about you broadly falls into information we receive about Contacts from our Clients. A Client may provide Personal Information about Contacts to us through the Services. For example, when a Client uploads their Subscriber List, or when a Contact signs up for a Client’s Subscriber List on a FlyEasy Empty Leg Alerts signup form, the Client may provide us with certain contact information or other Personal Information about the Contact such as their name, email address, or telephone number. The Contact may have the opportunity to update some of this information by electing to update or manage their preferences via an email they receive from the Client.
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.
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, or altering your data, by emailing us at firstname.lastname@example.org. 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 email@example.com.
- 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 Contacts through the Services, we act as a processor on behalf of our Clients. In such cases, if you are a Contact 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 individual Clients, you should contact the relevant Client that is using the Services, and refer to their separate privacy policies.
If you no longer want to be contacted by one of our Clients through our Services, please unsubscribe directly from that Client’s Subscriber List or contact the Client 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 Client of your request.
We respond to all requests we receive from individuals 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.
Clients 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 firstname.lastname@example.org. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Clients cannot opt out of these messages unless you cancel your FlyEasy account and Services.
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 email@example.com.
FlyEasy accounts require a username and password to log in. Clients must keep their username and password secure, and never disclose it to a third party. Because the information in a Client’s FlyEasy account is so sensitive, account passwords are hashed, which means we cannot see a Client’s password. We can however provide Clients with instructions on how to reset their password.
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 Clients have the ability to access and delete the data within their FlyEasy accounts.
- Whether our Clients 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.