Introduction

At FLYR, Inc., we care about your privacy and want you to be familiar with how we collect, use and share information. This Privacy and Cookie Policy (the “Policy”) describes our practices in connection with the Personal Data that we collect, use and share through the FLYR’s website (currently available at flyrlabs.com) and any successor website, on both desktop and mobile web browsers (the “Website”); and through HTML-formatted email messages that we send to you. By providing Personal Data to us, you agree to the terms and conditions of this Policy and to us collecting, holding, using and disclosing your Personal Data in accordance with it.

This Privacy and Cookie Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy and Cookie Policy.

1. The Data We Collect About You
2. How Your Personal Data is Collected
3. Cookies
4. Pixel Tags
5. Do Not Track Signals
6. Using Your Personal Data
7. Sharing Your Personal Data
8. Aggregated/Anonymous Data
9. Third Party Sites
10. International Data Transfer
11. Security
12. Retention
13. Our Policy on Children
14. Sensitive Personal Data
15. Your Rights
16. Complaints
17. Contact Information
18. Glossary

It is important that you read this Privacy and Cookie Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy and Cookie Policy supplements other notices and privacy policies and is not intended to override them.

Particularly Important Information

Who We Are: FLYR is made up of different legal entities, details of which can be found below:

FLYR, Inc.
3205 Pico Blvd. Santa Monica, CA 90405 USA

FLYR Poland sp z o.o.
Pana Tadeusza 2 Kraków, Poland 30-727

FLYR Netherlands B. V.
Westermarkt 2 1016 DV Amsterdam, Netherlands

This Privacy and Cookie Policy is issued on behalf of FLYR, Inc. so when we mention “FLYR”, “FLYR Labs”, “we”, “us” or “our” in this Privacy and Cookie Policy, we are referring to the relevant company in the FLYR, Inc. group responsible for processing your data. For purposes of applicable data protection legislation, the data controller of your Personal Data is:

FLYR, Inc.
3205 Pico Blvd.
Santa Monica, CA 90401 USA

Contact Details: If you have any questions about this Privacy and Cookie Policy, including any requests to exercise your rights, you may contact us at:

Attn: Compliance Team
FLYR, Inc.
3205 Pico Blvd.
Santa Monica, CA 90405 USA
compliance@flyrlabs.com

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.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1. The Data We Collect About You

As used in this Policy, “Personal Data” includes (i) 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, email address and telephone number; or (ii) an opinion about an identified individual or an individual who can be reasonably identified from the opinion, regardless of whether such opinion is true. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, or social media account ID.
• Contact Data includes billing and/or physical address, email address and telephone numbers.
• Employment Data includes data about your professional life such as Curriculum Vitae or cover letter.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Technical Data includes internet protocol (IP) address, your Media Access Control (MAC) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, your interactions with our Website, and other technology on the devices you use to access this Website.
• Usage Data includes information about how you use our Website.

2. How Your Personal Data is Collected

We collect information about you in the following ways:

Information You Give Us Directly. This includes:

• Identity and Contact Data you provide to us when you correspond with us by phone, email or otherwise; and
• Marketing and Communications Data, such as your preferred means of communicating with us, when you voluntarily provide it.

Information We Receive from Social Networking Sites. Our Website 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 Receive from Other Sources. We may also collect information about you from the following other sources:

1. Technical Data from analytics providers such as Google based in the United States;
2. Identity and Contact Data from data brokers and aggregators.
3. Identity and Contact Data from your friends and other people with whom you are connected on social media platforms;
4. Identity and Contact Data from your friends and other people with whom you are connected on social media platforms;

Information We Collect Automatically. We automatically collect Technical and Usage Data about you and your computer or mobile device when you access the Services from your computer or mobile device’s web browser.

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
Strictly Necessary Cookies	These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Performance Cookies	These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Functional Cookies	These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies	These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies	These cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

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 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. Pixel Tags

We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ Personal Data.

5. Do Not Track Signals

We also may use cookies and other tracking technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.

6. Using Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message, or as otherwise required under applicable law. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and, if you are based in the European Union, which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Marketing
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing.

We may use your Identity, Contact, Technical, Usage and Data 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 services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of service purchases governed under separate agreements.

Change of purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. Sharing Your Personal Data

We may share your Personal Data as follows:

• Third Party Advertisers. We may share with your consent Personal Data with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
• 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 us and such marketing communications are served by or using our affiliates.
• 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.
• 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) with your express consent to the disclosure or where your consent may be reasonably inferred from the circumstances.

8. Aggregated/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 analyze usage patterns in order to make improvements to our Services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website or Website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy and Cookie Policy.

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. 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 Website, 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.

11. Security

We have put in place appropriate organizational, technical and administrative measures to protect Personal Data within our organization. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

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, please immediately notify us of the problem by contacting us using the details in Section 17 below. 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.

12. 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).

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 whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Section 15, “Your Rights” below for further information.

In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

13. Our Policy on Children

Our Website is 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 17 below. We will delete such information from our files as soon as reasonably practicable.

14. Sensitive Personal Data

We do not collect and ask that you please do not send us or otherwise disclose to us through the Website 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). We also do not collect nor expect to receive from you any information about criminal convictions and offenses.

15. Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights:

• Request access to your Personal Data
• Request correction of your Personal Data
• Request erasure of your Personal Data
• Object to processing of your Personal Data
• Request restriction of processing your Personal Data
• Request transfer of your Personal Data
• Right to withdraw consent

If you wish to exercise any of these rights, please contact us using the details in Section 17 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.

No fee usually required
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.

16. 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: compliance@flyrlabs.com. We will reply to your complaint as soon as we can. We hope to resolve any complaint brought to our attention.

If you are based in Australia or the European Union, please note that you have the right to make a complaint at any time to your national regulator for data protection issues (the Office of the Australian Information Commissioner at www.oaic.gov.au if you reside in Australia, or the relevant Data Protection Authority in your country of residence if you reside in the EU). We would, however, appreciate the chance to deal with your concerns before you approach the regulator so please contact us in the first instance.

17. Contact Information

We welcome your comments or questions about this Policy. You may contact us at compliance@flyrlabs.com or:

Attn: Compliance Team
FLYR, Inc.
3205 Pico Blvd.
Santa Monica, CA 90405 USA

18. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract 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.

Comply with a legal obligation means processing your Personal Data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the processing of Personal Data relating to you.

YOUR LEGAL 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 and to check that we are lawfully processing it.

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.

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.

Object to processing of your Personal Data 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 and freedoms.

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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• 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.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. 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.

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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit oag.ca.gov/privacy/ccpa