Effective: May 17, 2018
Flight Sim Labs Ltd (“we” or “us”) are committed to protecting and respecting your privacy.
- the Flight Sim Labs products and their installers;
- the Flight Sim Labs product web pages, as well as the support forums;
- our licensing and product download web systems
- the Flight Sim Labs support ticket system
- collect Personal Data and other information when you use this Website or run our products;
- use, handle and disclose collected information; and
- choices you have about the ways we collect and use the information.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us at firstname.lastname@example.org.
So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
- Always keep your data safe and private.
- Never sell your data.
INFORMATION WE COLLECT ABOUT YOU
We will collect and process the following data about you:
Information you give us: (“Submitted Information“)
- This is information you give us about you by running our Product installers, filling in forms on the Site, or by corresponding with us (for example, by e-mail or via our support ticket system on the Site). It includes information you provide when you register to use the forum system, download, install or register our Products, subscribe to any of our services, enter into any transaction on the Site, participate in discussion boards or other social media functions on the Site, enter a competition, promotion or survey and when you report a problem with a Product, Service, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, username, password and other registration information, identification document numbers, copies of identification documents (for example, passport, driving license and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
Information we collect about you and your device: (“Device Information“)
- Each time you run our Product Installer or visit our Site we will automatically collect the following information:
- technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, computer hardware or mobile device information and the type of mobile device you use;
- information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, device information;
Information to help us deliver our service to you: (“Third Party Information“)
- We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Flight Sim Labs Services), sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, customer service providers and developers. Information we may collect about you from such parties can include information which helps us to verify your identity.
USES MADE OF THE INFORMATION
Below is a summary of the key types of data that we make use of as part of the Flight Sim Labs Products and Services. For more information on how these types of data are used and for which purposes then please see the table below.
We use information held about you in the following ways:
- Submitted Information. We will use this information:
- to carry out our obligations arising from any transactions you enter into with us, to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
- to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
- to notify you about changes to our service;
- to facilitate social interactions through our services; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Device Information. We will use this information:
- to allow our support engineers to provide accurate and appropriate support when you request assistance;
- to administer our Site and our Products for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site and our Products to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Site and our Products safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Site and our Products about goods or services that may interest you or them;
- to verify your identity, protect against fraud, comply with anti-financial crime and piracy laws and to confirm your eligibility to use our products and services; and
- to comply with our regulatory obligations.
- Third Party Information:
- We will combine this information with information you give to us and information we collect about you.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
For example, our purchasing transaction processing business partner (currently Digital River Inc. via its eSellerate platform) may use fraud prevention agencies, including but not limited to agencies based in Europe and might include such agencies overseas.
If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymized personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users. In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.
Purposes for which we will use your personal data
We have set out below, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via our support system if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the paragraphs below.
What we use your information for:
To combat against fraud: To verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services and to help us better understand your financial circumstances and behavior so that we may make decisions about how we manage your Flight Sim Labs Account, we use Submitted Information, Device Information, Third Party Information, as our Legitimate Interests are: To develop and improve how we deal with financial crime, comply with our legal duties in this respect, as well as to comply with regulations that apply to us.
To provide a better personalized support experience: To allow our engineers to provide better support for you and your purchased Products, we use Submitted Information and Device Information, as our Legitimate Interests are: To ascertain the platform and usage where our products are installed, to help our customers solve technical issues and to comply with regulations that apply to us.
To help market and provide new products and services that interest you: To provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about; To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you To make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them; and to process applications for products and services available through us including making decisions about whether to agree to approve any applications, we use Submitted Information, Device Information, Third Party Information, as our Legitimate Interests are: to develop products and services for existing customers, to define types of customers for new products or services and to be efficient about how we fulfill our legal and contractual duties. For those activities, we might also seek your consent when we need it to contact you.
To keep the Flight Sim Labs Services up and running: To administer our Site for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer; To allow you to participate in interactive features of our services, when you choose to do so; To notify you about changes to our service; and as part of our efforts to keep our Site and the App safe and secure, we use Submitted Information and Device Information as our Legitimate Interests are to be efficient about how we fulfill our legal and contractual duties and to comply with regulations that apply to us.
What do we mean when we say:
Legitimate Interest: this means the interest of ours as a business in conducting and managing Flight Sim Labs to enable us to provide to you the Flight Sim Labs Products and Services and offer the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Our Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
We want to make it crystal clear how we use your data for marketing purposes and how you can ‘opt-out’ from receiving any marketing communications from us whenever you want.
PROMOTIONAL OFFERS FROM US
We may use your personal data (such as your Submitted Information, Location Information or transaction information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have signed up to and/or utilize the Flight Sim Labs Products and/or Services and, in each case, you have not opted out of receiving marketing notifications.
We will obtain your express opt-in consent before we share your personal data with any company outside the Flight Sim Labs group of companies for marketing or promotional purposes (for example, to send you our newsletter).
You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences by following the unsubscribe links on any marketing message sent to you or by sending us an email to email@example.com.
DISCLOSURE OF YOUR INFORMATION
DATA PROCESSING PARTNERS
We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Flight Sim Labs.
We send personal data to the following sets of data processors in order to perform the Flight Sim Labs Services:
- Purchasing transaction processing business partners (currently Digital River Inc. via its eSellerate platform)
- This is so we can help you with purchasing transactions and support;
- Fraud prevention agencies
- This is in order to verify your identity, protect against fraud, and to confirm your eligibility to use our products and services;
- Internet Service Providers
- This is in order to safely and securely store your data with Flight Sim Labs;
- Advertisers and analytics providers
- If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymized personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, men in Paris). In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience;
- We also use analytics and search engine providers that assist us in the improvement and optimization of our site;
We may also disclose your personal information in the following circumstances:
- If Flight Sim Labs or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to:
- (i) enforce or apply the General Terms of Service and/or the Business Terms and/or any other agreements between you and us or to investigate potential breaches; or
- (ii) protect the rights, property or safety of Flight Sim Labs, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
THIRD PARTY SERVICES PARTNERS
From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimize their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any company outside the Flight Sim Labs group of companies for these purposes.
You can withdraw your consent at any time after giving your explicit opt-in consent by contacting support via email and letting us know.
STORAGE SECURITY & INTERNATIONAL TRANSFERS
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
RETAINING YOUR INFORMATION
YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via email.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via email.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the Flight Sim Labs Products and Services and it is likely we will have to terminate your account.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Flight Sim Labs Products and Services). In this case, we may have to cancel your use of the Flight Sim Labs Products and Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via email.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Flight Sim Labs Products and Services to you. We will advise you if this is the case at the time you withdraw your consent.
REPETITIVE / EXCESSIVE REQUESTS
If your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Flight Sim Labs Products and Services). In this case, we may have to cancel your use of the Flight Sim Labs Products and Services but we will notify you if this is the case at the time.
You have the right to make a complaint at any time to the Office of the Commissioner for Personal Data Protection, the Cyprus supervisory authority for data protection issues (firstname.lastname@example.org). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.