Current as of September 10, 2023
Welcome, and thank you for your interest in Flight Data Technologies Inc. (“FDT”, “we,” or “us”), our web site at https://www.fdt.link (the “Site”), and all related web sites, downloadable software, mobile applications (including tablet applications), and other services provided by us and on which a link to this Privacy Notice is displayed, and all other communications with individuals though from written or oral means, such as email or phone (collectively, together with the Site, our “Service”).
This Privacy Notice (“Policy”) describes the information that we gather on or through the Service, how we use and disclose such information, and the steps we take to protect such information.
This Policy is incorporated into, and is subject to, the FDT Inc. Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Flight Data Technologies Inc. Terms of Service.
The addresses of our offices, where Flight Data Technologies Inc., is located, can be found at https://www.fdt.link/contact
“Client” means a customer of Flight Data Technologies Inc.
“Client Data“ means personal data, reports, addresses, and other files, folders or documents in electronic form that a User of the Service stores within the Service.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Public Area” means the area of the Site that can be accessed both by Users and Visitors, without needing to log in.
“Restricted Area” means the area of the Site that can be accessed only by Users, and where access requires logging in.
“User” means an employee, agent, or representative of a Client, who primarily uses the restricted areas of the Site for the purpose of accessing the Service in such capacity.
“Visitor” means an individual other than a User, who uses the public area, but has no access to the restricted areas of the Site or Service.
2. Roles & Responsibilities
FDT is the controller of your Personal Data, as described in this Privacy Notice, unless otherwise stated.
Please note that this Privacy Notice does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role such as a “service provider” in certain jurisdictions) on behalf of our Clients, including where we offer to our Clients various cloud products and services, through which our Clients (and/or their affiliates) connect their own websites and applications to our hosted platform, sell or offer their own products and services, send electronic communications to other individuals, or otherwise collect, use, share or process Personal Data via our cloud products and services. In such cases, FDT does not own, control or direct the use of any of the Client Data stored or processed by a Client or User via the Service. Only the Client or Users are entitled to access, retrieve and direct the use of such Client Data. The Client or the User is the data controller under the Regulation for any Client Data containing Personal Data.
For detailed privacy information applicable to situations where a FDT Client (and/or a Client affiliate) who uses FDT’s cloud products and services is the controller, please reach out to the respective Client directly. We are not responsible for the privacy or data security practices of our Clients, which may differ from those set forth in this Privacy Notice. If not stated otherwise either in this Privacy Notice or in a separate disclosure, we process such Personal Data in the role of a processor or service provider on behalf of a Client (and/or its affiliates), who is the responsible controller of the applicable Personal Data.
If your Personal Data has been submitted to us by or on behalf of a FDT Client and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Client directly.
FDT is largely unaware of what Client Data is actually being stored or made available by a Client or User to the Service and does not directly access such Client Data except as authorized by the Client, or as necessary to provide Services to the Client and its Users.
Except as provided in this Privacy Notice, FDT does not independently cause Client Data containing Personal Data stored in connection with the Services to be transferred or otherwise made available to third parties.
FDT is not responsible for the content of the Personal Data contained in the Client Data or other information stored on its servers at the discretion of the Client or User nor is FDT responsible for the manner in which the Client or User collects, handles disclosure, distributes or otherwise processes such information.
3. The Information We Collect
We collect different types of information from or through the Service.
3.1 Information you provide directly to FDT
3.2 Information Collected by Clients
A Client or User may store or upload Client Data into the Service. FDT has no direct relationship with the individuals whose Personal Data it hosts as part of Client Data. Each Client is responsible for providing notice to its customers and third persons concerning the purpose for which Client collects their Personal Data and how this Personal Data is processed in or through the Service as part of Client Data.
3.3 Automatically Collected Information
3.4 Information that we collect from third parties
4. How We Use the Information We Collect
We use the information that we collect in a variety of ways in providing the Service and operating our business, including the following:
We use the information – other than Client Data - to operate, maintain, enhance and provide all features of the Service.
We process Client Data solely in accordance with the directions provided by the applicable Client or User.
We use the information:
Should this purpose require FDT to process Client Data, then the data will only be used in anonymized or aggregated form.
In addition to the purposes mentioned above, we may use your information for the following purposes:
4.5 Legal Bases for Processing Personal Data (for United Kingdom and European Economic Area and other relevant jurisdictions)
If you are an individual in the United Kingdom, the European Economic Area (EEA), or of another relevant jurisdiction, we collect and process information about you only where we have a legal basis or bases for doing so under applicable laws. The legal bases depend on the products and services that your organization has purchased from FDT, how such products and services are used, and how you choose to interact and communicate with FDT’s websites, systems, and whether you attend FDT events. This means we collect and use your Personal Data only where:
Where we rely on legitimate interests to process your Personal Data, you can object to that processing as described below under “Your Choices.” In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. FDT may also process other information that constitutes your Personal Data for direct marketing purposes and you have a right to object to FDT’s use of your Personal Data for this purpose at any time.
4.6 Additional Limits on Use of Your Google User Data
Notwithstanding anything else in this Privacy Notice, if you provide FDT access to your Google data (e.g., when you enable the email sync feature with your Google account), FDT’s use of that data will be subject to these additional restrictions:
FDT’s use of information received and FDT’s transfer of information to any other app from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
5. To Whom We Disclose Information
Except as described in this Notice, we will not intentionally disclose the Personal Data or Client Data that we collect or store on the Service to third parties without the consent of the applicable Visitor, User or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
5.1 Unrestricted Information
Any information that you voluntarily choose to include in a Public Area of the Service, such as a public profile page, will be available to any Visitor or User who has access to that content.
5.2 Other Users in Your Company Account
Certain information about your use of the FDT Services is available to the administrator(s) of your FDT Account and, depending on the settings chosen by the Users of the Account, also to other Users for the purposes of providing the FDT Services.
5.3 Service Providers
We work with third party service providers who provide website, application development, hosting, maintenance, security and fraud detection, and other services for us. These third parties may have access to, or process Personal Data or Client Data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
5.4 FDT Communities, Marketplace and Other User Generated Content
We make available various community forums and self-help support materials, as well as blogs and other means for you to post information on our websites. This information you post is publicly-available information that you choose to disclose and it may be read, collected, and processed by others that visit these websites. Except for username (which may be your real name) and the details that you choose to include in your profile, the categories of data disclosed in these circumstances will depend on what information you choose to provide. Your posts and certain profile information may remain even after you terminate your FDT account. We urge you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information you have posted on the websites if you so request, as described in Section 10 "Your Choices" below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
5.5 Social Media
FDT’s websites may use social media features, such as the Facebook “like” button, LinkedIn and Twitter sharing features, and other similar widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share content with others within your network. Social Media Features are either hosted by the respective social media network, or hosted directly on our websites. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website, the latter may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile. Your interactions with Social Media Features are governed by the privacy policies (and any other applicable terms) of the respective companies that provide the relevant Social Media Features.
5.6 Advertising and Marketing
5.8 Non Personally Identifiable Information
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our Clients’, Users’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Service, all of the foregoing being subject to additional limits on use of your data as stated in this Privacy Notice.
5.9 Law Enforcement, Legal Process and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or (v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
5.10 Change of Ownership
6. Data Security
At FDT, we take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. These measures have been audited and certified to industry standards. However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and other authentication factors, as well as maintaining the security of your devices. If you believe your Personal Data has been compromised, please contact us as set forth in the “Contact” section. If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
7. International Data Transfers
FDT may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, FDT will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with FDT’s obligations.
In particular, we offer the following safeguards if FDT transfers Personal Data from jurisdictions with differing data protection laws:
Privacy Shield; FDT participates and complies with the EU-U.S. Privacy Shield Framework set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information of individuals in the European Union. FDT Inc. has been certified by the Department of Commerce that it adheres to the Privacy Shield Principles. Please note that we do not rely on the EU-US Privacy Shield as a data transfer mechanism. To learn more about the Privacy Shield program and to view our certification, please visit https://www.privacyshield.gov/welcome. In compliance with the Privacy Shield Principles, FDT commits to resolving complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact FDT’s Data Protection Officer at dpo@FDT.link. FDT has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) concerning unresolved Privacy Shield complaints concerning human resources data and non-human resources data transferred from the EU. In any matters relating to the EU-U.S. Privacy Shield Framework, FDT is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
8. Minors and Children’s Privacy
Protecting the privacy of young children is especially important. Our Service is not directed nor intended to children under the age of 18, and we do not knowingly collect Personal Data from children under the age of 18. If you are under 18 years of age, then please do not use or access the Service at any time or in any manner. If we learn that Personal Data has been collected on the Service from persons under 18 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 18 years of age has obtained an Account on the Service, then you may alert us at privacy@FDT.link and request that we delete that child’s Personal Data from our systems.
9. Data Retention
We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.
For FDT CRM Service:
10. Your Choices
10.1 Your rights with respect to information we hold about you as a controller
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “Contact” section. At your request, we will have any reference to you deleted or blocked in our database. Additionally,
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact FDT’s Data Protection Officer at dpo@FDT.link.
10.2 Navigation Information
You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature. You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.
10.3 Opting out from Commercial Communications
You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe' function included in all such messages or by sending an email to the address provided in the “Contact ” section. Please note that you will continue to receive essential notices and emails such as account notification emails (password change, renewal reminders, etc.), security incident alerts, security and privacy update notifications, and essential transactional and payment related emails.
10.4 Information processed on FDT Client’s behalf
FDT has no direct relationship with the Client’s customers or third party whose Personal Data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client or User they deal with directly.
FDT Clients can delete, amend or block access to any Personal Data by contacting FDT Support.
11. Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights to understand and request that we disclose details about how we handle your Personal Data. To learn more about how we collect, use, disclose, and share your Personal Data, please see below.
11.1 Categories of Personal Data Collected
In the preceding 12 months, we have collected the following categories of Personal Data about California consumers. We may collect this Personal Data directly from you, from third parties, and from your interactions with us. For additional details about the Personal Data that we collect and the sources from which we collect this Personal Data, please review Section 3 above. The Personal Data categories are:
We may retain this Personal Data for as long as is needed for the purpose(s) for which it was collected and no longer than is relevant and reasonably necessary. Our retention periods vary based on business, legal and regulatory needs.
11.2 Business and Commercial Purposes for Collection; Disclosures for a Business Purpose
We may collect all of the above categories of Personal Data to run our business and carry out our day-to-day activities, as described above in Section 4. We have disclosed each of these categories of Personal Data with our service providers for various business purposes, as described above in Section 5, in the preceding 12 months.
11.3 Categories of Personal Data Sold or Shared for Cross-Context Behavioral Advertising
In the preceding 12 months, we have disclosed the above categories of Personal Data to third-party advertising partners, such as in connection with our use of tracking technologies for cross-context behavioral advertising or by providing lists of email addresses for potential customers, so that we can reach you across the web with advertisements for our products and services. This may be considered “sharing” or a “sale” under the CCPA. You can read more about our sharing and sales activities above in Section 3 and Section 5. FDT does not have actual knowledge that it sells or shares the Personal Data of consumers under 16 years of age.
11.4 Your Rights
The CCPA gives you certain rights regarding the Personal Data we collect about you:
You may also opt out by broadcasting an opt-out preference signal like the Global Privacy Control (GPC), but please note that this signal will be linked to your browser only. If you wish to learn more about the GPC and how to use a browser or browser extension incorporating the GPC signal, you can visit the GPC website here.
11.5. How to Exercise your California Rights
If you would like to make a request and exercise your rights described above, please contact us via privacy@FDT.link
12. Do Not Track (DNT) requests
Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.
In the meantime, you may opt out of receiving interest based advertising from advertising networks by visiting the following websites: http://www.aboutads.info/consumers and http://www.networkadvertising.org. This will opt you out of many – but not all - of the interest-based advertising activities in which we or third parties engage. Choices you make may be browser and device specific. If you delete your cookies or use a different browser or a different computer or device, you may need to update your opt-out choices.
13. Changes and Updates to this Notice
Please revisit this page periodically to stay aware of any changes to this Notice, which we may update from time to time. If we modify the Notice, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Notice has become effective indicates that you have read, understood and agreed to the current version of the Notice.
Please contact us with any questions or comments about this Notice, your Personal Data, our use and disclosure practices, or your consent choices by email at privacy@FDT.link. If you have any concerns or complaints about this Notice or your Personal Data, you may contact FDT’s Data Protection Officer by email at dpo@FDT.link.