Privacy Policy

INTRODUCTION

AirMatrix Inc. (“AirMatrix”, “we”, “us”) created this Privacy Policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through our web platform (the “Platform”) and our websites, including through our provision and your use of the Platform and our websites (“Websites”). Our Website provides certain informative and marketing information, and may subsequently be used to provide certain platform services related to information collected from the Platform(“Platform”).

The FAA has issued a Privacy Statement regarding information collected FAA LAANC USS Performance Rules. By signing up, you are agreeing that you have read and understood the FAA privacy statement: https://www.faa.gov/uas/programs_partnerships/data_exchange/privacy_statement

The privacy of our end users (“End Users”) is of great importance to us. By using the Platform in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.

2. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information relating to identifiable individuals (“Personal Information”).

This Privacy Policy does not apply to the practices of Subscribers. Subscribers are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Personal Information.

3.COLLECTION OF PERSONAL INFORMATION

3.1 Basic Account Information

In order to use the Platform and Service, End Users must submit their email address. We may limit use of the Platform to email addresses which match those provided by Subscribers. When you register for the Platform or create an End User account, We may collect your name, email address, business phone number and business address, and avatar/profile photo (“Account Information”). This information is entered directly by you into the Platform or Service (if applicable).

3.2 Information collected through the App

When you use our Platform, we use automatic data collection technologies (which may prompt you to take certain actions) to collect limited diagnostic and technical information about your use of the Platform and Third Party Drone Technologies, such as your location at the time of such usage (together, “Platform Usage Data”). The Platform also records information collected through the Third Party Technologies, but this information should not consist of Personal Information and accordingly is not subject to the terms of this policy.

3.3 Website Visitors

As you visit or browse the Website, we collect information about the device and browser you use, your network connection, your IP address, and information about the cookies installed on your device. This information is logged to help diagnose technical problems for analytics and for quality control purposes. We also collect Personal Information submitted by any visitor to our Website through messaging features we make available on our Website and use such information for the purpose of responding to your requests.

3.4 Platform Users

When subscribed for, End Users may be able to use the Platform. When you use the Platform, in addition to the information collected under section 3.1, we also use automatic data collection technologies (which may prompt you to take certain actions) to collect information about your use of the Platform. You may communicate with us through the Platform, and those communications will also consist of Personal Information.

3.5 LAANC Data

In this section, “FAA” means the Federal Aviation Administration;“LAANC” means the Low Altitude Authorization and Notification Capability developed by the FAA; and “LAANC Data” means the information entered into the Platform by Subscriber that AirMatrix either sends to the FAA or receives from the FAA, for the purpose of processing or managing LAANC authorizations for Subscriber. LAANC Data includes: (a) Personally Identifiable Information (PII) data that is collected, handled, shared, or stored, for the purpose of processing or managing LAANC authorizations (e.g., the operator’s first name, last name, phone number, and email address); and (b) All non-PII data collected, handled, shared, or stored, for the purpose of processing and managing LAANC authorizations (e.g., start date, time, and duration of the operation; maximum altitude; geometry airspace class(es); submission reference code; safety justification for non-auto-authorized operation; and aircraft registration number used to obtain an authorization from the FAA).

AirMatrix collects LAANC Data from Users in the course of providing the Services and uses LAANC Data for the purpose of providing the Services through the Platform to its End Users, and includes without limitation the following non-exhaustive list of uses:

● In the event that an Air Traffic Controller (ATC) intends to rescind an authorization, we share the operator’s phone number with the FAA such that ATC may opt to call the operator directly;

● If an authorization rescind message is received from the FAA, the Platform may use the operator’s phone number or email address to initiate resolution with the operator;

● In the event an operator wishes to request authorization for an operation, we collect operation details including the start time, end time, maximum altitude, boundary geometry of the operation, operator contact information including phone, email and name, and the operation category of 107 or 44809.

3.6 Cookies

We require authentication and authorization in order to process Account access. As such, we use cookies throughout the Platform Services to authenticate users.

A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our Website.

We use cookies to recognize devices and provide a personalized experience on Our Platform, or otherwise through the Platform. In particular, we use session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows us to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you’ve logged in and are required in order to use the Platform.

You may be able to set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website and/or Platform Services. We do not link any of the information we use in cookies to any personally identifiable information submitted by you when you are on the Website.

We also combine data derived from our usage of cookies with Account Information of registered users for the purposes set out in Section 3.1 above

4. USE OF YOUR PERSONAL INFORMATION

4.1 We use the Account Information to:

● authenticate access to your Account;

● link your account to the correct Subscriber (where applicable);

● send technical notices, updates, security alerts and support and administrative messages;

● provide and deliver the PlatformServices and features you request;

● provide customer service, support and otherwise communicate with you;

● prevent fraudulent transactions, unauthorized access to the Platform or Service, and other illegal activities;

● complete transactions, and send you related information;

● respond to comments, questions, and requests and provide customer service and support

● communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about us and our select partners;

● personalize and improve the Platform and otherwise customize your experience on the Platform

● monitor and analyze trends, usage, and activities in connection with the Platform and App

5. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

We process, access and store data, including Personal Information, on servers located in the United States. We also transfer Diagnostic Information to End User’s Subscribers.

By submitting Personal Information or otherwise using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada and the United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in theU.S. under lawful access regimes or court order.

6. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

6.1 Processing of data on behalf of Subscribers

As a service provider to organizations, we collect, analyze and disclose Platform Usage Data of individual Users to our Subscribers . In this role, we are a data processor, processing data upon instruction from Subscribers. This Platform Usage Data  is shared only with the relevant Subscriber.

6.2 Service Providers and Business Partners

We may from time to time employ third parties to perform tasks on our behalf and we may need to share Account Information and other Personal Information with them to provide certain services. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties we currently engage include third party companies and individuals employed by us to facilitate our services, including the provision of maintenance services, database management, Web analytics and general improvement of the Platform,and businesses who engage our Platform (to the extent provided for above).

6.3 Business Transfers

If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.

6.4 With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.

6.5 As required by law

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other End Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

satisfy any applicable law, regulation, legal process or governmental request; enforce our contracts or user agreement, including investigation of potential violations hereof; and detect, prevent, or otherwise address fraud, security or technical issues The above may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders.

7. RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. LAANC Data will be retained indefinitely, or until destroyed by the Operator.

8. ACCESS, CORRECTION AND ACCURACY

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

Any LAANC Data created by an operator may be destroyed by that operator through Palladium through the “delete” functionality. In the event this fails, the operator may contact AirMatrix by email to contact@airmatrix.ca to request their data is deleted, after which AirMatrix will manually delete the data. The operator may personally request a copy of their LAANC Data collected by AirMatrix by contacting AirMatrix via email at contact@airmatrix.ca.

9. RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”)

We generally process Personal Information in order to fulfill contracts we have with our End Users and to pursue our legitimate business interests listed above. Otherwise, we will obtain consent from an individual in respect of processing of Personal Information if required by law to do so. Further, individuals located in the EEA have certain rights under European law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of your personal data. Individual End Users, located in to the EEA who wish to exercise these rights, should contact us using the contact information below in Section 12. In certain instances we may be acting as the data processor of that information on behalf of the relevant Subscriber and queries may have to be redirected to that Subscriber.

Data Protection

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting announcement on our Website or Platform or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website, Platform or Platform after such changes have been first posted

11. Contact Details

Questions regarding this Privacy Policy, our privacy practices or your Personal Information should be directed to our Privacy Officer:

+1-647-889-3161

shayaan@airmatrix.io

Shayaan Haider