GENERAL INFORMATION
This Privacy and Cookie Policy (the “Policy”) describes our practices in connection with information and Personal Data that we collect, use and share through the ANRA website (currently available at www.anratechnologies.com and www.flyanra.com) and any successor website, on both desktop and mobile web browsers (the “Website”); through the software applications made available by us for use on or through computers and mobile devices (the “Apps”); through any drone or unmanned aircraft systems (“UAS”) that you own or operate and that is used in connection with any of our services (each, a “Drone”); and through HTML-formatted email messages that we send to you (collectively, including the Websites, the Apps and Drones, the “Services”). By providing Personal Data to us or using our Services, you agree to the terms and conditions of this Policy.
Particularly Important Information
Who We Are:
For purposes of applicable data protection legislation, the data controller of your Personal Data is:
ANRA Technologies, INC
25050 Riding Plaza, Suite 130
Chantilly, VA 20152
Changes to this Policy: We will post any modifications or changes to the Policy on our website. We reserve the right to modify the Policy at any time, so we encourage you to review it frequently. The “Last Updated” legend above indicates when this Policy was last changed. If we make any material change(s) to the Policy, we will post a notice on our website prior to such changes taking effect.
1 PURPOSES OF PROCESSING
We collect information about you in a range of forms, including Personal Data. As used in this Policy, “Personal Data” is as defined in the UK Data Protection Act 1998/the European Data Protection Directive 95/46/EC/General Data Protection Regulation 2018 and any successor legislation, this includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address and telephone number.
Why do we need your Personal Data?
We will only process your Personal Data in accordance with applicable data protection and privacy laws. We need certain Personal Data in order to provide you with access to the Services.
2 COLLECTING YOUR PERSONAL DATA
We collect information about you in the following ways:
Information You Give Us. This includes:
any Personal Data you choose to provide when you register to use our Services, including your name, postal address, email address, telephone number, username, credit or debit card information, driver’s license, password, social media account ID;
the Personal Data that may be contained in any video, comment or
other submission you upload or post to the Services;
the Personal Data you provide in connection with our contests, sweepstakes, and other promotions we run with the Services;
the Personal Data you provide when you report a problem with the Services, ask us to contact you or when we provide you with customer support;
the Personal Data you provide when you make a purchase through the Services; and
the Personal Data you provide when you correspond with us by phone, email or otherwise; and
the Personal Data you provide when you operate a Drone; and
any additional information, such as your preferred means of communicating with us, is collected when you voluntarily provide it.
Information from Social Networking Sites. Our Services include(s) interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
Information We Get from Others. We may also get information about you from other sources, for example, if you have agreed to share information with one of our developers, drone manufacturers, partners, people with whom you are friends or otherwise connected on social media platforms, or from other third parties. We may add this to information we get from our Services.
Information Automatically Collected. We automatically log information about you and your computer or mobile device when you access the Services.
Through your use of the App: When you download and use the App, we may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
When visiting our Services: We may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, your Media Access Control (MAC) address, screen resolution, the website you visited before browsing to our Services, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Services.
IP address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels of the Services, helping diagnose server problems, and administering the Services.
We may collect this information about you using cookies. Please refer to the sections on Cookies, Flash Technology and Pixel Tags below.
Automated Decision Making and Profiling.
We do not use your Personal Data for the purposes of automated decision-making. However, we may do so in order to fulfill obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
Other Information We May Collect: “Other Information” is information that does not reveal your specific identity or does not directly relate to an individual. We and our third party service providers may collect a variety of Other Information, including:
Drone information: When you use a Drone, we may collect its physical location, including its flight path, by, for example, using satellite, cell phone tower of WiFi signals. We may also collect a serial number or other information that identifies the Drone. We may use this information to provide you with personalized location-based services and content, including information regarding geofences and operation data, as well as enabling authorizations for operations by applicable airspace authorities.
Physical location: We may collect the physical location of your mobile device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. You may be able to allow or deny such uses of your device’s location, but, if you do, we may not be able to provide you with the applicable personalized services and content.
By aggregating information: Aggregated Personal Data does not personally identify you or any other user of the Services. For example, we may aggregate Personal Data to calculate the percentage of our users who have a particular postal code.
3 COOKIES
What Are Cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Services.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits the Services; and (2) third party cookies, which are served by service providers on the Services, and can be used by such service providers to recognize your computer or mobile device when it visits other websites.
Cookies We Use
Our Services use the following types of cookies for the purposes set out below:
Type of Cookie Purpose
Essential Cookies These cookies are essential to provide you with services available through our Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Services and help the content of the pages you request load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies These cookies allow our Services to remember choices you make when you use our Services, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of our Services which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Services.
Analytics and Performance Cookies These cookies are used to collect information about traffic to the Services and how users use the Services. The information gathered does not identify any individual visitor. It includes the number of visitors to our Services, the websites that referred them to our Services, the pages they visited on our Services, what time of day they visited our Services, whether they have visited our Services before, and other similar information. We use this information to help operate our Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.
We may use Google Analytics or similar tools for this purpose. Google Analytics or similar tools uses their own cookies. We only use these tools to improve how our Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies.
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Disabling Cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.
If you do not accept our cookies, you may experience some inconvenience in your use of [our Site/Application(s)/Services]. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit.
4 FLASH TECHNOLOGY
We may also use Flash cookies (which are also known as Flash Local Shared Object (“LSOs”)) on our Services] to collect and store information about your use of our Services. Unlike other cookies, Flash cookies cannot be removed or rejected via your browser settings. If you do not want Flash cookies stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. You can also control Flash LSOs by going to the Global Storage Settings Panel at https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our Services.
5 DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
6 USING YOUR PERSONAL DATA
We and our service providers use Personal Data for the following purposes:
Providing the functionality of the Services and fulfilling your requests.
To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service.
To provide you with information about your Drone or its intended flight path, including access to authorizations from applicable authorities for particular areas and information about various advisories.
To verify your identity in connection with your use of a Drone.
To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments, complaints, other customer service, or when you request a quote for or other information about our Services.
To complete your transactions and fulfill your purchase.
To allow you to send messages to another person if you choose to do so.
To allow you to publicly share your flight with others if you choose to do so. You may choose to turn this feature off by editing your general settings in the app and deselecting the option to “Make My Flights Public.”
To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
We will engage in these activities to fulfill our contractual relationship with you, our legitimate interest and/or to comply with a legal obligation.
Providing you with our newsletter and/or other marketing materials and facilitating social sharing
To send you marketing related emails, with information about our services, new products and other news about our company.
To facilitate social sharing functionality that you choose to use.
We will engage in this activity with your consent or where we have a legitimate interest.
Analysis of Personal Data for business reporting and providing personalized services.
To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
To better understand you, so that we can personalize our interactions with you and provide you with information, content, products and/or offers tailored to you.
To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services because we have a legitimate interest.
Allowing you to participate in sweepstakes, contests or other promotions.
We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
Some of these promotions have additional rules containing information about how we will use and disclose your Personal Data.
We use this information to fulfill our contractual relationship with you or where we have a legitimate interest.
Aggregating and/or anonymizing Personal Data.
We may aggregate and/or anonymize Personal Data so that it will no longer be considered Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose as intellectual Property of ANRA Technologies.
Accomplishing our business purposes.
For data analysis, for example, to improve the efficiency of our Services;
For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
For developing new products and services;
For enhancing, improving, or modifying our current products and services;
For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;
As we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others; and
As described in section 8, “Sharing of your Personal Data” below.
We engage in these activities to fulfill our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
7 SHARING YOUR PERSONAL DATA
We may share your Personal Data as follows:
Third Parties Designated by You. We may share your Personal Data with third parties where you have requested that we do so or provided your consent to do so. That may include:
airports, for example, when providing notice of a nearby operation or requesting authorization to operate;
other users, such as to anyone to whom you send messages through the Services; and
messaging or social services, such as message boards, chat, profile pages, blogs and other services to which you are able to post information and materials or communicate with other users of the Services (please note that any information you post or disclose through these services may become public and may be available to users of the Services and to the general public);
your friends or contacts associated with your social media account, other website users and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services account from your social media account.
By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Data shared with other users or with your social media account provider, please do not connect your social media account with your Services account, and do not participate in social sharing on the Services.
Our Third Party Service Providers. We may share your Personal Data with our third party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment information technology and related infrastructure provision, customer service, email delivery, auditing and other similar services. These third parties are only permitted to use your Personal Data to the extent necessary to enable them to provide their services to us. They are required to comply with appropriate security measures to protect your Personal Data.
If you make a payment through the Services, your Personal Data may be collected by a third party, and not by us, and will be subject to the third party’s privacy policy, rather than this Policy. We have no control over, and are not responsible for, this third party’s collection, use and disclosure of your Personal Data.
If you submit any Personal Data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy.
Third Party Advertisers. We may share Personal Data with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
Third Party Sponsors of Sweepstakes. We may share Personal Data with sponsors fo sweepstakes, contests and similar promotions.
Affiliates. We may share some or all of your Personal Data with our affiliates, in which case we will require our affiliates to comply with this Policy. In particular, you may let us share Personal Data with our affiliates where you wish to receive marketing communications from them.
Corporate Restructuring. We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Drone Manufacturers. We may share Personal Data with the manufacturer in connection with the operation of your Drone.
Other Disclosures. We may share Personal Data as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements, including public and government authorities outside your country of residence; (c) to enforce our Policy; (d) to enforce our terms and conditions; (e) to protect our rights, privacy, safety or property, and/or that of you, our affiliates or others; (f) to allow us to pursue available remedies or limit the damages that we may sustain;(g) ANRA will share data pursuant to l obligations with the regulatory bodies as applicable.
8 ANONYMOUS DATA
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the Personal Data we receive about you and other individuals whose Personal Data we collect. Anonymous data might include analytics information and information collected by us using cookies. We make Personal Data into anonymous data by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyses usage patterns in order to make improvements to our Services.
9 THIRD PARTY SITES
Our Services may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. Please read their privacy policies before you submit any data to them. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.
10 USER GENERATED CONTENT
You may share Personal Data with us when you submit user generated content to our Services, including via any promotion, forums, message boards, and blogs on our Services. Please note that any information you post or disclose on our Services will become public information, and will be available to other users of our Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Data, or any other information, on our Services. Such Personal Data and other information will not be private or confidential once it is published on our Services.
If you provide feedback to us, we may use and disclose such feedback on our Services, provided we do not associate such feedback with your Personal Data.
11 INTERNATIONAL DATA TRANSFER
Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA: Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Information. You may obtain a copy of these measures here.
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12 SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us using the details in Section 18 below.
13 RETENTION
We will only retain your Personal Data as long as reasonably required for you to use and provide you with the Services unless a longer retention period is required or permitted by law (for example for regulatory purposes).
14 OUR POLICY ON CHILDREN
Our Services are not directed to children under 16. If a parent or guardian becomes aware that his or her child has provided us with information without parental consent, he or she should contact us using the details in Section 19 below. We will delete such information from our files as soon as reasonably practicable.
15 SENSITIVE PERSONAL DATA
Do not send us, and do not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
16 YOUR RIGHTS
Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive Personal Data; (iv) any new processing of your Personal Data that we may carry out beyond the original purpose ; or (v) the transfer of your Personal Data outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out.
Access. You may access the information we hold about you at any time via your profile or by contacting us directly.
Amend. You can also contact us to update or correct any inaccuracies in your Personal Data.
Move. Your Personal Data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
If you wish to exercise any of these rights, please contact us using the details in Section 19 below. In your request, please make clear: (i) what Personal Data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
17 COMPLAINTS
We are committed to resolve any complaints about our collection or use of your Personal Data. If you would like to make a complaint regarding this Policy or our practices in relation to your Personal Data, please contact us at: legal@flyanra.com. We will reply to your complaint as soon as we can and in any event, within 45 days. We hope to resolve any complaint brought to our attention, however if you feel that your complaint has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.
18 CONTACT INFORMATION
We welcome your comments or questions about this Policy. You may contact us at
Attn: Privacy Compliance Officer
ANRA Technologies, INC
25050 Riding Plaza, Suite 130
Chantilly, VA 20152
19 EMPLOYEE PERSONAL DATA
ANRA commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to human resources data transferred from the EU in the context of the employment relationship. Please contact us to be directed to the relevant DPA contacts.