Privacy Policy

This Privacy Policy is incorporated by reference into the SkyTouch End User License Agreement (“EULA”). The terms “SkyTouch,” “we,” and “us” include SkyTouch LLC and our affiliates and subsidiaries. The Privacy Policy explains how SkyTouch may collect, use, and disclose information we obtain through the “Service.” Any capitalized terms used and not defined in this Privacy Policy shall have the meaning given to them in the EULA.

IMPORTANT NOTE: By accessing or using the Service, you expressly consent to SkyTouch’s collection, use, and disclosure of your Personal Information in accordance with the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the EULA.

Categories of Personal Data Processed by SkyTouch

PERSONAL DATA THAT IS PROCESSED WHEN YOU CREATE A SKYTOUCH ACCOUNT:

When you create a SkyTouch account, we ask you to provide your email address and name.

PURPOSES AND LEGAL GROUNDS:

(a) SkyTouch processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on SkyTouch’s legitimate interest in protecting the security of your account.

(b) SkyTouch also processes your email address for the purpose of sending you important information about your SkyTouch products, apps or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile. The legal ground for processing your email address and name for these purposes is SkyTouch’s legitimate interest in providing you important safety or other information about your SkyTouch products, apps or account or material changes to this Privacy Policy.

(c) For EU citizens, if you provide your opt-in consent to receiving marketing information from SkyTouch, SkyTouch will also process your email address for the purpose of sending you marketing information about SkyTouch products and apps, newsletters, and other occasional emails. For non-EU citizens, by giving SkyTouch your email address, you consent to receiving marketing information from SkyTouch and SkyTouch will also process your email address for the purpose of sending you marketing information about SkyTouch products and apps, newsletters, and other occasional emails. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your SkyTouch account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from SkyTouch are based on the preferences you provide in your SkyTouch account, the locale indicated by your Internet Protocol (IP) address, the types of SkyTouch devices you have added to your SkyTouch account, and any subscriptions included in your SkyTouch account. The legal ground for processing this data for this purpose is SkyTouch’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.

(d) SkyTouch also processes your email address to associate it with your SkyTouch account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

PERSONAL DATA THAT IS PROCESSED WHEN YOU MAKE A PAYMENT:

When you make payments through the Service, you may need to provide financial account information, such as your credit card number or bank account information, to our third-party payment processors. This information is provided directly to such payment processors, and we do not collect or store such information, though we may receive summary information about transactions that does not include credit card or bank account numbers.

PURPOSES AND LEGAL GROUNDS:

The legal ground for processing this data for these purposes is performance of a contract. We also process your personal data as part of our fraud detection processes. The legal ground for processing your personal data for that purpose is our legitimate interest in protecting SkyTouch and our customers from attempts to engage in fraudulent transactions.

Your financial account information, such as your credit card, is required to make a payment for a product. The legal ground for processing your email address for this purpose is based on SkyTouch’s legitimate interest in collecting payment for its services.

PERSONAL DATA THAT IS PROCESSED WHEN YOU ADD AN AIRCRAFT TO YOUR SKYTOUCH PROFILE:

When you add an aircraft to your SkyTouch account, we may ask for additional information, such as the make, model, series name, tail number, year and serial number of the aircraft.

PURPOSES AND LEGAL GROUNDS:

This information is processed to help SkyTouch function better by understanding the performance of your aircraft and allowing SkyTouch to make better calculations about your flight. The legal ground for processing this information is our legitimate interest in providing a better product that incorporates the performance of your aircraft in making calculations.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE SKYTOUCH TO CREATE AND FILE FLIGHT PLANS:

You can use SkyTouch to create flight plans and file those flight plans with applicable aviation authorities. When you do this, we process your name, phone number, address, aircraft details, date and time of the flight, and associated flight details.

PURPOSES AND LEGAL GROUNDS:

This information is processed to help you create flight plans and file them with applicable aviation authorities. The legal ground for processing this information is our legitimate interest in providing a tool to our customers to create and file flight plans.

PERSONAL DATA THAT IS PROCESSED USING THE LOCATION INFORMATION FROM YOUR MOBILE DEVICE:

When you use SkyTouch, we process the aircraft’s tail number, latitude, longitude, heading, barometric altitude, destination, estimated time enroute, and associated flight details. Without location information, SkyTouch navigational features will not function properly. This data is uploaded to your SkyTouch account.

PURPOSES AND LEGAL GROUNDS:

This information is processed to help you keep track of important details regarding your flights. The legal ground for processing this information is our legitimate interest in providing a tool to our customers to keep track of important flight details. In addition, SkyTouch’s navigational features help provide you with a safer flight.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE THE LOGBOOK FEATURE:

When you use the logbook feature on SkyTouch, we process information about your flights, such as the take-off and landing airports, dates and times, and notes you choose to submit.

PURPOSES AND LEGAL GROUNDS:

We process this data to provide our customers an automated tool for them to maintain these regulatorily required records in their pilot logs. The legal ground for processing this information is our legitimate interest in provider our customers an automated tool for them to maintain these regulatorily required records in their pilot logs.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE THE EAPIS FEATURE:

When you use the Electronic Advance Passenger Information System (“eAPIS”) feature on SkyTouch, we process traveler manifest information for each individual on an aircraft, notice of arrival information, and notice of departure information. The traveler manifest information for each passenger may include full name, date of birth, place of birth, citizenship, sex, passport number, passport country of issuance, passport expiration date, United States visa number or alien card number, and such other information as the Administrator of the Transportation Security Administration may deem reasonably necessary.

PURPOSES AND LEGAL GROUNDS:

We process this data to provide our customers an automated tool for eAPIS and maintain these as regulatorily required. The legal ground for processing this information is our legitimate interest in provider our customers an automated tool for them to maintain these regulatorily required records for eAPIS.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE THE APPLICATION:

When you use the SkyTouch app, we process information about you and your device including a device ID, IP address, mobile software and hardware information, pages or areas visited within the Service, what time said pages and areas are visited, and web browser information, so that we can provide and customize functionality, such as push notifications. You may also permit the Service to access your device’s contact list and photo storage. We may share information about your flight plan and fuel card information to fuel vendors to obtain fuel pricing information.

PURPOSES AND LEGAL GROUNDS:

We process this data to provide our customers with a better user experience. The legal ground for processing this information is our legitimate interest in providing a better product that provides the user with a better experience.

PERSONAL DATA THAT IS PROCESSED WHEN YOU COMMUNICATE WITH SKYTOUCH:

When you interact with our customer support representatives via email, telephone, or online, we collect personal data, such as your name, mailing address, phone number, email address, and contact preferences; and information about the SkyTouch products you own. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys.

When you contact SkyTouch for technical support, diagnostic data, including logs from the device on which you use our application, may be automatically uploaded to SkyTouch to help the technical support team resolve your concerns.

PURPOSES AND LEGAL GROUNDS:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is SkyTouch’s legitimate interests in providing quality product support.

PERSONAL DATA THAT IS PROCESSED WHEN YOU VISIT THE SKYTOUCH CAREERS PAGE:

When you interact with our careers page, we collect information you provide in applying for a job, including information contained on resumes or other documentation voluntarily provided by you to us in the job application process.

PURPOSES AND LEGAL GROUNDS:

We use this information to evaluate you for a career at SkyTouch. The legal ground for processing this information for the purposes is SkyTouch’s legitimate interest in hiring qualified candidates.

Categories of Recipients of Personal Data

AVIATION AUTHORITIES:

When you use SkyTouch to create and file flight plans, your flights plans and associated information are submitted to the applicable aviation authorities.

OTHER SERVICE PROVIDERS:

SkyTouch uses cloud services from third parties such as Vero and Zendesk, to assist in sending emails and to analyze the use and performance of SkyTouch products. Those services track the activities associated with emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. SkyTouch uses this data to analyze the level of engagement with its emails. SkyTouch uses third-party service providers such as AppCenter and Segment to help us better understand usage of the SkyTouch website and the SkyTouch app.

OTHER DISCLOSURES:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of SkyTouch assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information, and we disclaim any liability arising out of such entity’s failure to comply with the terms of the EULA or this Privacy Policy.

Transfers of Personal Data

SkyTouch is a global business. To offer our products, apps, and services, we may need to transfer your personal data to other SkyTouch companies in other countries. When you create a SkyTouch account, add personal data in your account profile, or upload data to your SkyTouch account, your personal data will be collected and stored on SkyTouch LLC’s servers in the United States. Personal data regarding individuals who reside in a country in the European Economic Area or in Switzerland is controlled by and processed by SkyTouch LLC.

Any transfers of personal data from SkyTouch companies in the European Economic Area ("EEA") or Switzerland to SkyTouch LLC in the United States is done pursuant to European Commission approved Model Contractual Clauses.

All SkyTouch companies are required to follow the privacy practices set forth in this Privacy Statement.

Cookies and Similar Technologies

WEBSITE:

To help analyze how you and other visitors navigate the SkyTouch websites, we compile aggregate statistics about site usage and response rates to help diagnose any problems with SkyTouch’s servers, administer the SkyTouch websites, and maintain user experience continuity across website pages and site visits, we, with assistance from third-party analytics service providers, collect certain information when you visit our site. This information includes IP address, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., links) that you click. We may use cookies, pixel tags, web beacons, clear GIFs or other similar tools on our sites or in our email messages to assist us in collecting and analyzing such information. We use this information to provide better, more relevant content on our sites, to identify and fix problems, and to improve your overall experience on our sites.

If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them.

If you reside in the European Union or other jurisdiction that requires us to obtain your consent to use cookies on our sites, then you will have an opportunity to manage your cookie preferences on the sites; except that certain cookies are required to enable core site functionality, and you cannot choose to disable those cookies.

SkyTouch APP:

We also collect data from users about their usage of the SkyTouch app. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. SkyTouch uses this data to improve the quality and functionality of the SkyTouch app; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products, apps, and websites so we can enhance the user experience and functionality of our products, apps, and websites.

Here are examples of third-party providers of analytics and similar services we currently use:

ANALYTICS SERVICES:

Google: Firebase, a Google service, is used to help us improve the user experience, identify and resolve the root causes of unexpected behaviors, and remotely control the rollout of new features within SkyTouch apps. For more information, see the Privacy and Security in Firebase document. Google Analytics is used to track website statistics and visitor demographics, interests, and behavior. We also use Google Search Console to help understand how our website visitors find our website and to improve our search engine optimization. For more information, see the Google privacy policy. You may opt out at https://tools.google.com/dlpage/gaoptout.

Information Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Neither SkyTouch, nor its affiliates, nor any of their respective employees, officers or agents or the provider of the internet services on behalf of SkyTouch (nor any other person involved in the management or establishment of the Service) can give any representation or warranty as to the absolute security of the data transmitted using the Service, and cannot give any guarantee that such data will not be compromised by bad actors. If you choose to provide data to or allow collection of data by SkyTouch, then you do so understanding the aforementioned risk.

By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice by mail.

Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at ynon.raz@gmail.com. If we learn that we have collected any Personal Information from children under 13 in a manner that is inconsistent with the U.S. Children’s Online Privacy Protection Act, we will promptly take steps to delete such information and terminate the child’s account as soon as practicable.

Marketing

We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. We may allow access to other data collected by the Service to send information we think may be useful or relevant to you. Note that we may use your name, usage history and email address without further consent for non-marketing or administrative purposes (such as notifying you of major updates, customer service needs, tips on using the Service, notifications of unused features of the Service, or items for which you have requested communication).

Legal and Similar Disclosures

We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) comply with the law; (iv) investigate, prevent, take action, or enforce compliance with regard to a violation of the EULA or this Privacy Policy; (v) investigate, prevent or take action regarding illegal activities or suspected fraud; or (vi) protect your, our, or others’ rights, property, or safety.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the bottom of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the SkyTouch website and through the SkyTouch app.

Retention of Personal Data

We will retain your personal data as long as your SkyTouch account is active. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

The personal data collected by SkyTouch is controlled by SkyTouch LLC’s Data Protection, which you can also contact by email at ynon.raz@gmail.com.

Your Rights in the European Union

If you reside in the European Union, you have the right under the General Data Protection Regulation to request from SkyTouch access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you may have similar rights under your local laws.

To request access to or rectification, portability or erasure of your personal data, or to delete your SkyTouch account, email ynon.raz@gmail.com

If you live in the European Union and you wish to exercise your right to restriction of processing or your right to object to processing, contact SkyTouch’s Data Protection, which you can also contact by email at ynon.raz@gmail.com. If you do not live in the European Union but you believe you have a right to restriction of processing or a right to object to processing under your local laws, please contact SkyTouch LLC at ynon.raz@gmail.com.

Your Rights in California

This section applies solely to the personal data of users who reside in the State of California ("consumers" or "you") and supplements the information contained in SkyTouch's Privacy Policy. We have included this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices: The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

• Access to Specific Information and Data Portability Rights. You have the right to request that SkyTouch disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information, if any; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• Deletion Request Rights. You have the right to request that SkyTouch delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (vi) engage in public or peer-reviewed research in accordance with Section 1798.105 (d)(6) of the CCPA; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; or (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
• Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: E-mail: ynon.raz@gmail.com or ynon.raz@gmail.com or write to us at the address listed above.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

• Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
• Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Contact Information: If you have any questions or comments about this notice, the ways in which SkyTouch collects and uses your information described in this section, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: ynon.raz@gmail.com or ynon.raz@gmail.com or write to us at the address listed above.

Your Rights in Brazil

This section applies solely to the personal data of users who reside Brazil ("consumers" or "you") and supplements the information contained in SkyTouch's Privacy Policy. We have included this section to comply with the General Law for the Protection of Personal Data (“LGPD”).

If you are a user located in Brazil, you may be able to exercise the following rights with respect to your personal information that we have collected, subject to certain limitations:

The right to confirmation of the existence of the processing. You have the right to ask that we confirm whether we process your personal data.

• The right to access the data. You have the right to access the personal data we hold about you and certain information about how we use it and who we share it with, including information about any public and private entities we have shared your personal data with.
• The right to correct incomplete, inaccurate or out-of-date data. If you want to correct or revise any of the data that we retain on you, you may do so by accessing your account and the information contained within it.
• The right to anonymize, block, or delete unnecessary or excessive data or data that is not being processed in compliance with the LGPD. Please note that, depending on the request, this may result in a suspension or discontinuation of certain services and is also governed by legal and/or contractual retention guidelines.
• The right to the portability of data to another service or product provider by means of an express request. We provide you with the ability to move any of your account data to a third party, at any time.
• The right to delete personal data processed with the consent of the data subject. You have a right to request the permanent deletion of your data, subject to certain exceptions. However, please note that exercising this right may result in a suspension or discontinuation of services and is also governed by legal and/or contractual retention guidelines.
• The right to information about the possibility of not giving consent and about the consequences of the refusal. You have the right to ask us to provide information about the possibility of not giving consent for the processing of your personal data and the consequences of such refusal.
• The right to revoke consent.

Exercising Data Portability and Deletion Rights

To exercise the data portability and deletion rights described above, please submit a verifiable consumer request to us by:

• Emailing us at ynon.raz@gmail.com

We will need to verify your identity before processing your request. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or a legal representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Last updated: June 1 2024