Welcome to FlyCode Inc
FlyCode Inc (“FlyCode”, “us”, “we”, or “our”) operates https://www.flycode.com/
SERVICE means the https://www.flycode.com/ website operated by FlyCode Inc and any services offered through the website or through engagement with Flycode.
PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit). (See additional explanation under Section 4 below)
COOKIES are small files stored on your device (computer or mobile device).
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively. DATA SUBJECT is any living individual who is the subject of Personal Data.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Service.
While using our Service, we may collect certain Personal Data about you which may include, but is not limited to:
(a) Business email address
(b) First name and last name
(c) Company and position information
(d) Phone number
(e) Address, State, Province, ZIP/Postal code, City
(f) Usage Data
(g) Location Data
You can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Service.
We also use the web analytics tool Google Analytics. This tool helps us understand users’ behaviour on our Service, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service provider is available at: www.google.com/policies/privacy/partners. Further information about your option to opt-out of this analytics service is available at: https://tools.google.com/dlpage/gaoptout.
Examples of Cookies we use:
(a) Session Cookies: We use Session Cookies to operate our Service.
(b) Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
(c) Security Cookies: We use Security Cookies for security purposes.
(d) Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
To learn more about our practices concerning cookies and tracking, please see our Cookie settings popup. For more information on our cookie and data collection technologies practices, you may also use the “Cookie settings” feature available in our Service depending on your location and activity on our Service, as applicable.
FlyCode Inc uses the collected data for various purposes and based on the ensuing lawful bases:
(a) to provide and maintain our Service; (Performance of a Contract (to the extent applicable); Legitimate Interest).
(b) to notify you about changes to our Service; (Performance of a Contract (to the extent applicable); Legitimate Interest).
(c) to allow you to participate in interactive features of our Service when you choose to do so; (Performance of a Contract
(to the extent applicable; Consent (to the extent applicable).
(d) to provide customer support; (Performance of a Contract (to the extent applicable); Legitimate Interest)
(e) to gather analysis or valuable information so that we can improve our Service; (Legitimate Interest).
(f) to monitor and analyze the usage of our Service; (Legitimate Interest).
(g) to detect, prevent and address technical issues; to support and enhance our data security measures, including for purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity. (Performance of a Contract (to the extent applicable); Legitimate Interest, Compliance with legal obligations).
(h) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; (Performance of a Contract (to the extent applicable); Legitimate Interest; Compliance with legal obligations)
(i) to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.; (Performance of a Contract (to the extent applicable); Legitimate Interest; Compliance with legal obligations)
(j) to provide you with news, special offers and general information about other goods, services and events, contests and promotions which we offer; you may always opt not to receive such information; (Performance of a Contract (to the extent applicable); Consent (to the extent applicable)).
(k) To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose; (Performance of a Contract; Legitimate Interest) for any other purpose with your consent, collected in accordance with applicable laws, as necessary.
(l) To comply with applicable laws and regulations; (Compliance with legal obligations)
(m) To comply with court orders and warrants, and prevent misuse of the Service, and to take any action in any related legal dispute and proceeding; (Performance of a Contract; Compliance with legal obligations; Legitimate interest)
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
We and our authorized Service Providers (as defined below) maintain, store and process personal data in Israel and other locations, as reasonably necessary for the proper performance and delivery of the Service, or as may be required by law.
FlyCode is headquartered in Israel, a jurisdiction which is considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to be offering an adequate level of protection for the personal data originating from the EEA, Switzerland and the UK, respectively. We transfer personal data from the EEA, Switzerland and the UK to Israel on this basis. For data transfers from the EEA, Switzerland or the UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO). You can obtain a copy by contacting us as indicated in Section 19 below.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by e-mail at email@example.com
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use of some of our Service (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our user or prospect, subject to any necessary collection of your consent as appropriate based on applicable laws. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to: Privacy@flycode.com, changing your communications preferences in your profile settings whilst being logged as a user to our Service (when the feature is available), or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
We may disclose personal data in the following ways:
(a) Disclosure for Legal Compliance.
We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
(b) Business Transactions, Affiliates and Subsidiaries.
We may share personal data internally within our group, for the purposes described in this Policy. In addition, should FlyCode or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
(c) Sharing your Feedback or Recommendations.
; If you submit a public review or feedback, note that we may (at our discretion) store and present your review on the Service. If you wish to remove your public review, please contact us at firstname.lastname@example.org
(d) Protecting Right and Safety.
We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of FlyCode and our employees, any of our Visitors or Users, or any members of the general public.
(e) Event Sponsors.
If you attend an event or webinar organized by us, or download or access an asset on the Website related to such an event, webinar or other activity involving third party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may be asked to consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will also be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned;
(f) Service Providers.
We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial, privacy and compliance advisors (collectively, “service providers“). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use the data as determined in our agreements with them.
For the avoidance of doubt, FlyCode may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
We implement industry-standard physical, procedural and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security
In certain circumstances, you may have the following data protection rights:
(a) the right to access, update or to delete the information we have on you;
(b) the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
(c) the right to object. You have the right to object to our processing of your Personal Data
(d) the right of restriction. You have the right to request that we restrict the processing of your personal information;
(e) the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
(f) the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
To request to exercise your rights please email us at email@example.com.
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj.
You may also have the right to lodge a complaint with the relevant Data Protection Authority about our collection and use of your Personal Data. If you are a resident of the EU, , please contact your local data protection authority in the European Economic Area (EEA) for more information.
(a) users can visit our site anonymously;
(d) users are able to change their personal information by emailing us at Privacy@flycode.com.
Our Policy on “Do Not Track” Signals:
We honour Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
This policy describes the categories of personal information we may collect and the sources of such information (in Section 3 above), and our retention (Section 7) and deletion rights (Section 10) practices. We also included information about how we may process your information (in Sections 4 through 9), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Service as described in Section 8 above, if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Service, or direct us to disclose your personal data to third parties, or as otherwise described in Section 8 above.
If you have any questions or would like to exercise your rights under the CCPA, you can contact firstname.lastname@example.org
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
FlyCode is both a “data controller” and “data processor” of User Data. Such data is processed by FlyCode for its own purposes (as described in Section 5 above), as an independent ‘controller’.
In rare circumstances, part of the code that our Customers have engaging with the Service may include minimal personal data, which in such an event we will process on behalf of our Customers as a “data processor” of such personal data. Accordingly, FlyCode processes Customers’ personal data strictly in accordance with our Customers’ reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such Customers. In such instances, our service providers who process such Customer personal data on our behalf are the “sub-processors” of such personal data. Our Customers are solely responsible for determining whether and how they wish to use our Service, and for ensuring that all individuals using the Service on their behalf, as well as all individuals whose personal data may be included in the code engaging with the Service have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of personal data through our Service are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, submitted by their users and other individuals whose data they process through the Service.
Our Service is not intended for use by or to attract children (i.e. individuals considered minors under applicable law).
We do not knowingly collect personally identifiable information from minors. If you become aware that a minor has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from minors we will promptly take steps to remove that information from our servers.