Version 2.2, last updated 06 June 2024

Previous versions available here.

INTRODUCTION

Welcome to SCALEFLYT, a cloud-based drone management and mission planning service to simplify and enhance your drone operations.

To use SCALEFLYT, you will first need to indicate that you are aware of and have read this Privacy Notice and consent to us using your Personal Information in accordance with its terms. You will also need to review and accept our Terms of Use. It is our responsibility to ensure the privacy of our users and our Privacy Notice is intended to set out clearly the circumstances and ways in which we will collect, store and use the data you provide us with, to deliver and enhance the ScaleFlyt Services. We may only ever use your Personal Information in a manner that is consistent with your rights and our obligations at law.

Please read this Privacy Notice carefully and ensure that you understand it.  You may only use SCALEFLYT if you accept the Terms of Use and indicate that you are aware of and consent to us processing your personal data in accordance with this Privacy Notice. If you do not consent to us processing your Personal Information in accordance with this Privacy Notice, you may not use our Services and must immediately discontinue any use of our Services.

It may become necessary for us to introduce changes or amendments to this Privacy Notice from time to time. If we need to introduce a change to this Privacy Notice, we will write to you by email or notify you through the Services to make you aware of the change, and how it affects you and your use of the Services. You will always have the ability to withdraw your consent to us processing your data in accordance with this Privacy Notice should you wish to do so. However, if you do withdraw your consent, you understand and acknowledge that you will no longer be permitted to access or use the Services and must immediately cease to use them in accordance with our Terms of Use.

1. DEFINITIONS AND INTERPRETATION

In this Policy, the following terms shall have the following meanings:

"Cookie"	Means a small text file placed on your computer or device by our Services when you visit certain parts of them and/or when you use certain features. Details of how we use Cookies in our Services are set out in our Cookies Policy at Section 10 of this Privacy Notice;
"Data Protection Law"	Means the legislation and regulations applicable to data protection and data privacy which apply to your use of our Services, including but not limited to the UK Data Protection Act 2018, the European Union ("EU") General Data Protection Regulation, the California Consumer Privacy Act 2018 and the Privacy Act 1988 (Cth) in Australia;
"Data Controller"	Means the entity which, alone or jointly with others, determines the purposes and means of the processing of Personal Information;
"Data Processor"	Means the entity which processes Personal Information on behalf of the Data Controller;
"Personal Information"	Means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
"Platform"	Means the SCALEFLYT web platform (available at https://platform.scaleflyt.com ) through which we provide the substantial part of the Services;
"Privacy Notice"	Means this privacy notice and all other information, documents, materials, laws and regulations referenced within it;
"we/us/our" or "Thales"	Means Thales AVS France SAS, as further defined in Section 2 below;
"You/your"	Means you, a user of the Services as further defined in the Terms of Use;
"Service(s)" or "SCALEFLYT"	Means the services (as further described in the Terms of Use) which we may provide to you from time to time through the Platform and the Website.
"Terms of Use"	Means the latest version of the SCALEFLYT Terms of Use which detail your rights and responsibilities as a user of the Services and are available at: https://www.scaleflyt.com/terms-of-use
"User Account"	Means your individual user account required to access and use our Services;
"Website"	Means the SCALEFLYT website (www.scaleflyt.com) through which we provide news, pricing, marketing material and other information about the Services we offer.

2. ABOUT US

SCALEFLYT is provided by Thales AVS France SAS, a company registered in France under company number 612039495, whose registered address is 75-77 Avenue Marcel Dassault 33700 MERIGNAC, France.

3. WHAT DOES THIS PRIVACY NOTICE APPLY TO?

This Privacy Notice applies to your use of the SCALEFLYT Service. Please note that through the SCALEFLYT service you may share data with services provided by third-parties through links to services, integrated applications or websites (these are detailed in Section 8 and 9 and the Appendix). Note that we do not control how your data is collected, stored or used by third-party services, applications or websites and we recommend that you review the privacy policies applicable to any such third-party services, applications or websites before providing any data to them.

Data you share with us is held privately and securely, but in some cases we may, under Data Protection Law, share it with third-parties, either to make certain elements of the Services available to you or for safety purposes. Data that we share in this way is explained in more detail within Section 8 and 9 and the Appendix.

The only other circumstance in which we may share other data we hold about you is in the event we receive a legal court order or warrant properly served in accordance with applicable local laws which requires us to do so.

4. YOUR RIGHTS

4.1 Under Data Protection Law, your rights include (depending on the applicable laws in your country of residence):

(a) Your right of access – You have the right to ask us for copies of your Personal Information.

(b) Your right to know – You have the right to request that we inform you of:

(1) The categories of Personal Information we have collected about you.

(2) The categories of sources from which we collected Personal Information about you.

(3) The business or commercial purpose for collecting or selling Personal Information about you.

(4) The categories of Personal Information that we will disclose about you for a business purpose; and

(5) The categories of third parties with whom we will share Personal Information about you.

(c) Your right to rectification – You have the right to ask us to rectify Personal Information you think is inaccurate. You also have the right to ask us to complete data you think is incomplete.

(d) Your right to erasure – You have the right to ask us to erase your Personal Information in certain circumstances.

(e) Your right to restriction of processing – You have the right to ask us to restrict the processing of your Personal Information in certain circumstances.

(f) Your right to object to processing – You have the right to object to the processing of your Personal Information in certain circumstances.

(g) Your right to data portability - You have the right to ask that we transfer the Personal Information you gave us to another organisation, or to you, in certain circumstances.

(h) Your right to file a complaint – If you are a resident of the state of California, you have the right to lodge a complaint with the competent data protection authority.

4.2 You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at the details provided in Section 11 if you wish to make a request.

4.3 If you have any cause for complaint about our use of your Personal Information, please contact us using the details provided in Section 11 and we will aim to resolve the problem for you. If we are unable to help, you also have the right to lodge a complaint with an applicable regulatory authority such as the French Data Protection Authority (CNIL) , for residents in the EEA, their national supervisory authority or, for residents in Australia, the Office of the Australian Information Commissioner (OAIC), whose contact details can be found at https://www.oaic.gov.au.

4.4 You can contact the CNIL for further information about your rights or if you wish to raise a complaint relating to our use of your Personal Information, on the following URL: https://www/cnil.fr/fr

5. WHAT DATA DO WE COLLECT?

We currently collect some or all the following personal and non-personal information, either directly or indirectly, depending on your use of the Services:

5.1 Your name, which you provide when creating a User Account.

5.2 The email address you provide when creating a User Account.

5.3 The geographical region / country you select when creating a User Account and your language and currency preferences

5.4 Your profile picture, which you may choose to upload via User Account settings.

5.5 Information related to a specific feature or output you have requested the Services to provide you with (for example, data relating to your use of geographical mapping and search features within our Services, or information you provide us through the technical support or content reporting features);

5.6 Information, data and content which you input in to our Services to be stored or used alongside your User Account from time to time, this includes data like your contact details, mission planning and operational data, drone equipment and inventory management information and images, pre and post-flight logs, customer/client information, chat, messages and any other similar categories of information which you provide to be stored in connection with your User Account or your use of any feature of SCALEFLYT;

5.7 Payment information, billing address and financial data provided to our third-party payment service provider in accordance with Section 9 and the Appendix, in order for us to provide you with a secure payment and checkout service for in-application purchases.

5.8 Analytical information and metadata concerning your use and interaction with our Services to help us improve our products and services. Such information will be anonymised wherever possible and may include, for example:

(i) Whether our Services are used in a commercial or recreational capacity.

(ii) The frequency with which our Services are used.

(iii) Trends in the use of certain features within our Services; and

(iv) User analytics provided by Cookies (see Section 10 for more information on the Cookies we use).

5.9 Other information or data that you may explicitly ask us to store from time to time.

6. HOW IS YOUR DATA USED?

6.1 All Personal Information we collect is stored securely and processed for no longer than is necessary for the purposes it was first collected. It is our responsibility to ensure that we observe and safeguard your rights under applicable Data Protection Law and, unless otherwise agreed, we will normally only hold your Personal Information for as long as you have a User Account with us which you have accessed within the past 24 months, but we may hold your Personal Information for a longer period of time if required by applicable law. You may update or delete your User Account at any time by contacting our customer services team at the details provided in Section 11, or through the relevant settings within the Services (where applicable).

6.2 We will only use your Personal Information if we have a lawful basis to do so. Lawful bases are likely to include any one or combination of the following:

(a) Because it is necessary for us to perform a contract with you.

(b) Because you have consented to our use of your Personal Information (i.e. consenting for us to contact you by email or consenting for your Personal Information to be shared with a third-party service in order to provide you with a feature of SCALEFLYT); or

(c) Because we are otherwise obliged to do so by applicable law.

Specifically, we use your data:

6.2.1 To provide you with and manage the data stored within your User Account;

6.2.2 To contact you to provide you with important notifications concerning your use of the SCALEFLYT (but not for marketing purposes, unless you have explicitly opted-in to receive marketing communications);

6.2.3 To contact you in connection with security incidents, investigations or otherwise in connection with our legal and regulatory obligations.

6.2.4 To provide you with access to and functionality within our Services (for example, to enable you to securely log-in to our Services, make secure payments and recall information which you have saved within our Services).

6.2.5 To personalise and customise your user experience within our Services.

6.2.6 To provide our Services to you (for example, we require your full name, country of residence, and email address to enter into a contract with you).

6.2.7 To notify you of changes to our Services or any of the material terms relating to your use of our Services (such as the Terms of Use or this Privacy Notice).

6.2.8 To respond to your technical or customer support requests.

6.2.9 To provide you with correspondence relating to other services which you may have opted in for, such as newsletters or information on product upgrades, marketing information, etc. (you may unsubscribe or opt out of such other services at any time by clicking to 'unsubscribe' in any related communication); and

6.2.10 To conduct market or product research for our own purposes to improve our products and services (not for third parties).

6.2.11 We may facilitate the sharing of your information with other users of the Services for the purposes of providing you with networking and community features. Such features and the information shared with other users will be explained to you within the Services. You may choose to opt-in or opt-out at any time by contacting us at the details provided in Section 11, or through the relevant settings within the Services (where applicable), however this may limit or prevent you from using networking and community features.

6.3 With your permission and only where permitted by law, we may use your data for marketing purposes which could include contacting you by email with information, news and offers about the Services. We will not send you any unsolicited marketing, generic marketing or spam and will always take reasonable measures to ensure that we protect your rights and comply with Data Protection Laws.

6.4 You have the right to withdraw your consent to us using your Personal Information at any time, and to request that we delete your Personal Information in accordance with your rights at Section 4, depending on the applicable Data Protection Laws in your jurisdiction. However, in some cases this may limit or prevent us from continuing to provide you with the Services. You can request this at any time using the contact details provided in Section 11.

6.5 Insofar as we have received your e-mail address from another user of the Services through the "Invite a member" feature (or any comparable invitation-based feature), we may keep your e-mail address for up to 30 days in order to send you information about this invitation. If you choose not to accept an invitation, we will not continue to hold your e-mail address (unless you wish otherwise). If you do not wish to be contacted, you can tell us at any time using the link(s) in the invitation email.

7. WHERE IS YOUR DATA STORED?

7.1 With the exception of 7.2 below, we will only store your data within the France or European Economic Area unless otherwise required by your local laws.

7.2 Our third-party service providers and partners may transfer, process and store your payment data and other Personal Information on systems located within the United States or other countries outside of the United Kingdom. Further detail is provided in the Appendix below.

7.3 The security and protection of your data is extremely important to us. We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Measures we implement to secure and protect your data include:

(a) Use of secure data centres and databases.

(b) Use of encryption.

(c) We limit access to your Personal Information to those employees and contractors who have a business need to know and whom are subject to obligations of confidentiality. Our employees and contractors are subject to data protection awareness training and may only process your Personal Information upon our instruction.

8. THIRD PARTY FEATURES THAT MAY REQUIRE YOUR INFORMATION

8.1 To provide you with certain features within SCALEFLYT, we may need to share your Personal Information with third parties from time to time. We will only share your Personal Information with third parties with your express permission. In such cases:

8.1.1 You will be asked whether you wish to consent to the specific third-party data sharing. You will be presented with a description of the information the third-party is requesting us to provide them with on your behalf. You will have an opportunity to review and accept any terms of use / privacy terms applicable to the third-party's use of the information. Note that we do not control how such third parties use your data and you should review any applicable privacy terms of the third-party in detail before consenting to us sharing your information with them to ensure you are happy to provide it;

8.1.2 If you have consented to third-party data sharing pursuant to 8.1.1 above, you may at any time withdraw your consent by contacting our customer services team at the details provided in Section 11, however, in some cases withdrawing your consent to third-party data sharing may mean that we can no longer continue to provide you with the Services (see Section 9); and

8.1.3 Should you withdraw your consent in accordance with 8.1.2 above, we will no longer provide or update the information shared with the concerned third-party, however this will not explicitly delete information already held by the third-party up to that point. Without obligation, we will endeavour to pass on your data removal request to the concerned third-party, however insofar as your data is being held by that third-party in its capacity as a data controller, this will not explicitly delete the information held by them and it shall remain your responsibility to manage this directly with that third-party.

8.2 Further to Section 5.7, we may compile statistics about the use of our Services, this might include (without limitation) web traffic data, service usage patterns, sales and user statistics, diagnostic information, in-service user searches, however we will anonymise any of such data which could be used to identify you. Insofar as permitted by law, we may from time to time share such data with commercial investors, advertisers, technical support partners and other associated third parties.

8.3 Further to Section 6.2(c), we may under certain circumstances be legally obligated to disclose information to appropriate authorities, for example, in the event of legal proceedings, a valid court order or the valid instruction of a governmental authority. Such information may include Personal Information, but in all cases, we shall only disclose that part of the Personal Information which we are strictly obligated to disclose by law.

9. HOW WE SHARE YOUR INFORMATION WITH THIRD PARTIES

9.1 Certain features of the Services require us to share your data with trusted third-party suppliers for processing on our behalf (such as the payment service provider provided by Stripe and secure log-on provided by Microsoft). These features are not optional and cannot be disabled. Therefore, if you do not consent to the sharing of your data with such third parties, we cannot provide you with the Services and you must cease to use the Services immediately. Data processing activities conducted on our behalf by third parties are detailed in the Appendix below.

10. COOKIES POLICY

10.1 Our Services may place and access certain first-party Cookies on your computer or mobile device (where applicable). First-party Cookies are those placed directly by our Services and are used only by us. We use Cookies to improve your user experience within our Services and our Cookies have been carefully chosen to ensure that your privacy and Personal Information is protected in accordance with this Privacy Notice.

10.2 You may also receive selected third-party Cookies on your computer or device. Third-party Cookies are those placed by services other than our own with our permission. We use third-party Cookies to improve our Services based on user interaction.

10.3

(a) When accessing the Website, prior to any Cookies being placed on your computer or mobile device you will be shown a Cookies notice or banner, which will prompt you to either accept or decline the placing and use of Cookies whilst accessing our Services. By choosing “Accept” on the Cookies banner, you are consenting to the placing and use of Cookies as further described below. Cookies enable us to provide you with the most optimum user experience. By choosing “Decline” on the Cookies banner, your information will not be tracked when you visit the SCALEFLYT website. A single cookie will be used in your browser to remember your preference not to be tracked. If you choose not to select “Accept” or “Decline” on the Cookies banner, Cookies will not be placed or used whilst accessing our website.

(b) When accessing the Platform, you will be notified on the Launch Page that Strictly Necessary Cookies are being used in accordance with our Privacy Notice. Further information on Strictly Necessary Cookies is provided in 10.4 below. You can access our Privacy Notice to review the Cookies we use at any time from the Platform Launch Page, the user account registration page, or from any other page within the Platform by navigating to the “Help” link.

10.4 Certain features of our Services require Cookies to function; these Cookies are deemed to be strictly necessary by applicable law. Cookies that are strictly necessary for the provision of our Services are shown below. Whilst we do not require your consent to place these Cookies, it is still important that you are aware of them. You may still deny these Cookies through your device's browser settings, but please note that our Services may not function as intended (or at all).

10.5 The following first party Cookies may be placed on your computer or device:

Name of Cookie(s)	Purpose	Strictly Necessary
No first party cookies at this time	-	-

The following third-party Cookies may be placed on your computer or device:

Name of Cookie(s)	Provider	Purpose	Strictly Necessary
__hs_opt_out	HubSpot	To remember not to ask visitor to accept cookies again	Yes
__hs_do_not_track	HubSpot	Prevents tracking code from sending information to HubSpot	Yes
__hs_initial_opt_in	HubSpot	Prevents banner from displaying when visitors are browsing in strict mode	Yes
hs_ab_test	HubSpot	To serve visitors same version of an A/B test page they’ve seen before	Yes
<id>_key	HubSpot	For visits to password-protected page, future visits to the page from the same browser do not require login again.	Yes
__hsmem	HubSpot	Contains encrypted data that identifies the membership user when they are currently logged in	Yes
hs-membership-csrf	HubSpot	To ensure that content membership logins cannot be forged	Yes
hs_langswitcher_choice	HubSpot	To save the visitor’s selected language choice when viewing pages in multiple languages	Yes
__cfduid	HubSpot	Set by HubSpot’s CDN provider, Cloudflare. It helps Cloudflare detect malicious visitors and minimizes blocking legitimate users	Yes
__cfruid	HubSpot	Set by HubSpot’s CDN provider because of their rate limiting policies. It expires at the end of the session	Yes
__hstc	HubSpot	For tracking visitors	No
hubspotutk	HubSpot	Keeps track of a visitor’s identity	No
__hssc	HubSpot	Keeps track of sessions	No
__hssrc	HubSpot	Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser	No
__stripe_mid	Stripe	Fraud prevention and detection	Yes
__stripe_sid	Stripe	Fraud prevention and detection	Yes
m (or "guid")	Stripe	Fraud prevention and detection	Yes

Please find links below to the Cookie Policies of the third-party Cookie providers listed in our Cookies table:

• Stripe Inc - https://stripe.com/cookies-policy/legal
• HubSpot - https://legal.hubspot.com/cookie-policy

10.6 You may at any time delete Cookies on your computer or mobile device (where applicable) through your browser settings, however, doing so may result in a degradation or loss of the Services.

11. CONTACT US

For all general enquiries please contact customer service:

Via the Service:

By clicking on the “Help” menu.

Directly:

Email: customerservice@scaleflyt.com

For Personal Information protection specific matters:

Email: privacy@scaleflyt.com

12. CHANGES TO OUR PRIVACY NOTICE

We may change this Privacy Notice from time to time for any reason, including accounting for changes in the Services or applicable law. Any changes will be communicated to you via our Services, posted on our website(s) (where applicable) and/or emailed to you where we hold your email address. To continue to access and use our Services you will need to consent to us processing your data in accordance with the revised Privacy Notice. The next time you log-in to the Services, you will be prompted to acknowledge and provide your consent to the revised Privacy Notice. If you do not provide your consent to the revised Privacy Notice you will not be able to access and continue to use the Services and you must immediately cease any use of the Services. In such case, refunds (where applicable) will be processed in accordance with the relevant section of the Terms of Use.

APPENDIX

HOW WE SHARE YOUR INFORMATION WITH THIRD PARTIES

To enable us to provide the Services we use third party service providers who may also process your Personal Information. This processing is generally done on our behalf. Occasionally where stated, these third parties may also process data for their own purposes. To use the Services, you must consent to the processing in accordance with their privacy policies, whether or not you make any purchase. Please therefore ensure that you have read and understood each of these privacy policies. Further information regarding these third parties, the data processing, and the privacy policies is set out below.

Stripe:

Stripe Inc. and its affiliates ("Stripe") provide a payment service to support the processing of secure transactions within the Services.

Stripe uses the following information (where applicable) to process data on our behalf:

• Your bank account details.
• Your payment card details including expiration date and CVC.
• Your cardholder name.
• Your email address.
• Your unique customer ID.
• Your order ID.
• The date/time/amount of your transaction.
• Origin of transaction.
• Your business VAT number (where applicable); and
• Your billing address.
• Mouse activity, browsing patterns, screen resolution and other technical information about your browser and device

Stripe use this information to support an e-commerce platform and facilitate payments for users.

Stripe may also use your Personal Information for their own purposes. Specifically, Stripe may use your Personal Information to:

• Monitor, prevent and detect fraudulent payment transactions, and to prevent harm to us, you and third parties.
• Comply with legal or regulatory obligations applicable to the processing and retention of payment data, including applicable anti-money laundering and know-your-customer compliance.
• Analyse, develop and improve their products and services; and
• Provide their products and services to you and us.

Data Transfers:

Users located in the UK, EEA or Switzerland may have their Personal Information transferred to contracted third-parties in other countries (see: https://stripe.com/gb/privacy#international-data-transfers ). Stripe’s Global Privacy Policy ensures that a User’s Personal Information (if transferred) adheres to appropriate legal transfer mechanisms.

For more information, please refer to the Stripe Global Privacy Policy available athttps://stripe.com/gb/privacy

Microsoft:

Microsoft Corporation ("Microsoft") uses the email address you provide at registration to provide a secure user authentication and log-on.

The Microsoft Privacy Statement is available at: https://privacy.microsoft.com/en-gb/privacystatement

HubSpot:

HubSpot Ireland Limited ("HubSpot") in conjunction with its affiliate group companies and third-party providers provide a customer relationship management (CRM) service.

When you access or interact with the Website or the Platform, we share your Personal Information with HubSpot in order for them to provide this CRM service. They may share your Personal Information with their own third-party providers.

HubSpot use the following information (where applicable) to process data on our behalf:

• Your email address
• Your first and last name
• Your physical address
• Your phone number

HubSpot may also use your Personal Information for their own purposes. Specifically, HubSpot may use your Personal Information to:

• Develop and improve HubSpot’s Subscription Services
• Inform HubSpot’s Sales and Marketing Strategies
• Facilitate HubSpot machine learning (data will be anonymised)

(For more information on how HubSpot uses Personal Information as a Data Controller please refer to the HubSpot privacy notice available at: https://legal.hubspot.com/product-privacy-policy )

Data Transfers:

For Users located in the UK, EEA or Switzerland, HubSpot may also transfer a User’s Personal Information to contracted third parties located in other countries. HubSpot ensures that this transfer is compliant with appropriate legal transfer mechanisms.

The HubSpot Product Privacy Policy is available at https://legal.hubspot.com/product-privacy-policy

What3words:

What3words Limited ("What3words") provides a service to translate a three-word address into GPS/geographical co-ordinates.

The What3words Privacy Policy is available at https://what3words.com/privacy .

Google Analytics:

Google LLC (“Google”) provides a free website analytics service. The service aggregates multitudes of statistical data regarding website visits and translates this data into an intelligent analytics report. We use these reports to actively measure and improve our Services. The data used by Google to provide this service does not include Personal Information.

The Google Privacy Policy covers the Google Analytics service and is available at: https://policies.google.com/privacy

Single Sign-on Services:

You can register and log in to our Services using third-party single sign-on services ("SSO") such as Google, Microsoft and LinkedIn. These services will allow the third-party to authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our registration form. You may also have the option of sharing additional information with us from your SSO account. If you choose to provide such information, you are consenting for us to use, store and share that information in a manner consistent with our Privacy Notice. We will only ever use Personal Information from your SSO account to confirm your identity and register your User Account for our Services.

Please refer to the Google , Microsoft or LinkedIn privacy documentation for further information on how your Personal Information is stored and used by these third-parties.

The version was last updated on 6 June 2024.