Privacy Policy

Last Updated: July 06, 2020

Kittyhawk.io, Inc. (“Kittyhawk,” “we,” “us,” and “our”) provides products and services for commercial drone operations, flight logging, data management, and other related activities (“Services”).  Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and share your personal information and to assist you in exercising the privacy rights available to you.

SCOPE

This Privacy Policy applies to personal information processed by us in our business, including on our websites, applications, and other online or offline offerings (collectively, the “Services”).

CONTENTS

1. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on whether you are a customer, user, applicant or visitor, and the requirements of applicable law.

Information You Provide to Us

  • Account Creation. When you create an account, we may collect your name, email address, phone number, username, and password.
  • Your Communications with Us.  We collect personal information from you such as email address or phone number when you request information about our Services, sign up for our newsletter, request customer or technical support, or otherwise communicate with us.
  • Drone Operations. We may collect information about your drone operations such as aerial vehicle flight plan, log data, operator information, and other information that you choose to upload to the Services.
  • LAANC Data. We may collect Low Altitude Authorization and Notification Capability (“LAANC”) data from drone operators such as name, phone number, email address, location and flight boundaries, submission reference code, safety justification for non-auto-authorized operation, operator certificate information, and aircraft registration number used to obtain an authorization from the Federal Aviation Administration (“FAA”).
  • Payment Information. We collect personal information and details associated with your payments. Any payments made via the Services are processed by third-party payment processors, such as Stripe. You can read Stripe’s Privacy Policy at: https://stripe.com/privacy. Kittyhawk does not directly collect or store any payment card information provided to the Services, but it may receive information associated with your payment card information (e.g., your billing details).
  • Surveys.  We may contact you to participate in surveys.  If you decide to participate, you may be asked to provide certain information which may include personal information.
  • Interactive Features.  We may offer interactive features such as forums, blogs, or social media pages.  Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
  • Conferences and Trade Shows. We may attend conferences and trade shows where we collect personal information from individuals who interact with or express an interest in Kittyhawk and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.

Information Collected Automatically or From Others

  • Automatic Data Collection.  We may collect certain information automatically when you use the Services.  This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services.  Information we collect may be associated with accounts and other devices.In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.  We may combine your information with information that other people provide when they use our Services.
  • Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising technologies.  We, as well as third parties that provide content or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.  Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.
    •  Cookies.  Cookies are small text files placed in visitors’ computer browsers to store their preferences.  Most browsers allow you to block and delete cookies.  However, if you do that, the Services may not work properly.
    •  Pixel Tags/Web Beacons.  A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page.  The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

For more information about our use of cookies, including the cookies on our website, please see our Cookie Policy at https://kittyhawk.io/cookie/.

  • Analytics.  We use service providers to collect information regarding visitor behavior and visitor demographics on our Services. These include:

For a full list of our Analytics service providers and more information about their privacy practices, please see our Cookie Policy at https://kittyhawk.io/cookie/.

  • Information from Other Sources. We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you.  For example, if you access our Services through a third-party application, such as an app store or a third-party login service, we may collect information about you from that third-party application that you have made public via your privacy settings.  Information we collect through these services may include your name, your user identification number, your username, location, gender, birth date, email, profile picture, and your contacts stored in that service.  This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.

2. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to:

Fulfill our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;
  • Providing access to certain areas, functionalities, and features of our Services;
  • Communicating with you about your account, activities on our Services and policy changes;
  • Undertaking activities to verify or maintain the quality or safety of a service;
  • Processing your financial information and other payment methods for products or Services purchased;
  • Processing your LAANC Data in compliance with federal law, the LAANC Memorandum of Agreement, and LAANC Performance Rules; and
  • Allowing you to register for events.

Analyze and improve our Services pursuant to our legitimate interest, such as:

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
  • Undertaking research for technological development and demonstration;
  • Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
  • Improving, upgrading or enhancing our Services; 
  • Developing new products and Services;
  • Ensuring internal quality control;
  • Verifying your identity and preventing fraud;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Enforcing our terms and policies; and
  • Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:

You have certain choices about how we share your and our marketing practices.

  • Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
  • Auditing relating to interactions, transactions and other compliance activities; and
  • Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

Use of De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

How We Use Automatic Collection Technologies.  We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services.  Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality.
  • Performance Related.  We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services.
  • Functionality Related.  We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services.  This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed.

More information about each category may be found in our Cookie Policy, available at https://kittyhawk.io/cookie/.

Notice Regarding Third Party Websites, Social Media Platforms.  The Services may contain links to other websites, and other websites may reference or link to our website or other Services.  These other websites are not controlled by us.  We encourage our users to read the privacy policies of each website and application with which they interact.  We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications.  Visiting these other websites or applications is at your own risk.

Our Services may include publicly accessible blogs and social media pages.  By using such Services, you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.  In addition, social media buttons such as Facebook, LinkedIn, and Twitter (that might include widgets such as the “share this” button or other interactive mini-programs) may be on our site.  These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly.  These social media features are either hosted by a third party or hosted directly on our site.  Your interactions with these features apart from your visit to our site are governed by the privacy policy of the company providing it.

3. DISCLOSING YOUR INFORMATION TO THIRD PARTIES

Except as provided below, we do not disclose or sell your personal information.

Service Providers.  We may share any personal information we collect about you with our third-party service providers.  The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; marketing services; and vendors to support the provision of the Services.

FAA. When you use the LAANC Services, we may share LAANC Data with the FAA, pursuant to law, federal regulation, the LAANC Memorandum of Agreement, and the LAANC Performance Rules. 

Airspace Partners. You may opt in to sharing flight-related data across the Kittyhawk platform and also with airspace partners, such as FAA-approved UAS Service Suppliers.

Business Partners.  We may provide personal information to business partners with whom we jointly offer products or services.  In such cases, our business partner’s name will appear along with ours on our website.

Affiliates.  We may share personal information with our affiliated companies. 

Disclosures to Protect Us or Others.  We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers.  If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

International Data Transfers.  You acknowledge that all LAANC Data processed by us will be transferred, processed, and stored in the United States in accordance with the LAANC Memorandum of Agreement. Other information that is not LAANC Data processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.  We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well.  Further details can be provided upon request.

4. YOUR CHOICES

General. You have certain choices about your personal information.  Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below.  Even if you opt out, we may still collect and use non- personal information regarding your activities on our Services and for other legal purposes as described above.

Email and Text Message Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails.  Note that you will continue to receive transaction-related communications such as emails or text messages regarding products or Services you have requested.  We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy). If you receive an unwanted text message from us, you may respond “Stop” to opt out of receiving future text messages.

We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. For additional information about how to stop or restrict the use of cookies or Technologies on your device, please see our Cookie Policy, available at https://kittyhawk.io/cookie/. You can also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.  

Your Privacy Rights.  In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict or object to our uses processing of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, if applicable, where such requests are permitted by law; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information held about you by Kittyhawk, subject to certain exceptions prescribed by law; and (vii) not be discriminated against by us for exercising your privacy rights. 

You also have the right to access, request a copy, or request deletion of your LAANC Data collected by Kittyhawk. 

If you would like to exercise any of these rights, please contact us as set forth below.  We will process such requests in accordance with applicable laws. To protect your privacy, Kittyhawk will take steps to verify your identity before fulfilling your request.

5. DATA RETENTION

We store the personal information and LAANC Data we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.  To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services 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 Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

7. CHILDREN’S INFORMATION

The Services are not directed to children, as defined by applicable local law, and we do not knowingly collect personal information from children.  If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below.  If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

8. OTHER PROVISIONS

Supervisory Authority. If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

California Residents. Under the CCPA, California residents have certain rights around our collection, use, and sharing of their personal information as explained in the “Your Privacy Rights” section above. If you wish to exercise any of your rights as a California resident, please contact us as set forth below. In exercising any rights under the CCPA, we will ask certain questions in order to verify your identity and your status as a California resident. An agent may also submit a request on your behalf, but we may require that you verify the agent has been authorized by you.

We have collected the following categories of personal information from California consumers in our role as a business within the last 12 months. The categories of sources from which we collect personal information are set forth above. We collected this personal information for the business and commercial purposes described in this Privacy Policy.

Categories of Information Collected Information Examples
Identifiers Name, unique personal identifier, online identifier, Internet Protocol address, email address, or account name
Commercial information Records of services purchased
Internet or other electronic network activity Browsing history, information on a consumer’s interaction with an internet website, application, or advertisement
Geolocation data Location reported by browser or inferred from IP address
Professional or employment-related information Current employer
Personal information categories listed in the categories above, but references in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name or telephone number

We do not “sell” personal information as such term is defined by the CCPA, nor do we have actual knowledge that we have “sold” any personal information of minors under 16 years of age. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose to the following categories of third parties:

Categories of Information Disclosed Categories of Third Parties to Which Personal Information was Disclosed
Identifiers Service providers, FAA
Commercial information Service providers
Internet or other electronic network activity Service providers
Geolocation data Service providers, FAA
Professional or employment-related information Service providers
Personal information categories listed in the categories above, but references in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e))
Service providers, FAA

Changes to Our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion.  If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.  You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Kittyhawk.io, Inc.
Attn: Legal
legal@kittyhawk.io
49 Powell Street
San Francisco, CA 94102