A. INTRODUCTION AND DEFINITION

This Privacy Policy describes the privacy practices of Lufty in connection with the Lufty app and related services we provide (together also as the “Services”). Please also read our Terms of Use which sets out the terms governing the Services. This document provides information on the manner and scope of the collection and usage of personal data by use – the company Lufty.app s.r.o., a company with a registered office in Prague, Czech Republic (“Lufty”). Lufty provides you with the Services and thus it is in the position of a data controller of your personal data in the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).

B. WHAT DATA WE COLLECT

When you use the Lufty app, we may collect data about you, including but not limited to:

• Account information such as name, surname, year of birth, gender, username, photographs you added, flights, tasks to your account and contact details such as email;
• App usage information such as information about how you use the Lufty app and interact with us, including date, time and geo-location information as well as your speed & altitude while using the Lufty app;
• Device data such as version of your iOS, model of your device, hash of your UUID, push tokens, Google Advertising ID, Apple ID for Advertising, screen resolution, IP address (and the associated country in which you are located, and other information about the device you are using to visit the Lufty app;

C. HOW WE COLLECT DATA

We obtain personal data directly from you, especially from the registration of your account, communication, or from the usage of the Lufty app and due to the provision of the Services. In addition, personal data may also come from publicly available sources, registers and records. Furthermore, we may have obtained personal data from third parties who are authorized to access and process your personal data and with whom it cooperates, as well as from information from social networks and the Internet that you have placed there yourself.

D. PURPOSE AND LEGAL BASIS OF THE PROCESSING OF DATA

Lufty collects and uses personal data in order to provide the Services, including but not limited to: (i) use of all features of the Lufty app, (ii) creating and maintaining your account, (iii) communicating with you about the Services, (iv) sending you updates, alerts, notifications or responding to your queries.

Furthermore, we may also collect and process personal data if it is necessary for other legitimate purposes of Lufty, for example:

• to develop or improve the Lufty app;
• to send you marketing and promotional communications;
• where necessary for compliance, such as the collection and provision of personal data in accordance with regulatory requirements or decisions of respective authorities;
• if it is necessary to protect our users or to enforce our Terms of Use.

E. TRANSFER AND TERM OF DATA STORAGE

Personal data will be kept only for the time necessary to fulfil the purposes described herein (or other purposes, which will be provided), or otherwise required by applicable laws and other internal regulations. We will only pass on personal data to other third parties if you are duly acquainted with the terms of the transfer and express your prior consent.

F. YOUR RIGHTS

Lufty does everything to ensure that your data is processed properly and, above all, securely. You are guaranteed the rights described in this article, which you can exercise with Lufty:

The right to information about the processing of your personal data

You are entitled to request information from us whether personal data is processed or not. If personal data is processed, you have the right to request information from us, in particular on the identity and contact details of Lufty, its representatives and, where applicable, the data protection officer, the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient, about the list of your rights, about the possibility to contact the Office for Personal Data Protection, about the source of processed personal data and about automated decision-making and profiling.

If we intend to further process your personal data for a purpose other than the one for which they were obtained, we will provide you with information on this other purpose and other relevant information before the said further processing. The information provided to you in the exercise of this right is already contained in this Privacy Policy, but this does not prevent you from requesting it again.

Right of access to personal data

You are entitled to request information from us as to whether or not your personal data is being processed and, if so, you have access to information on the purposes of the processing, the categories of personal data concerned, recipients or categories of recipients, the retention period of personal data, information about your rights (the right to request rectification or deletion from us, restrictions on processing, to object to such processing), the right to submit a complaint with the Office for Personal Data Protection, information on the source of personal data, information on whether automated decision-making and profiling takes place and information on the data used,procedure, as well as the significance and expected consequences of such processing for you, information and guarantees in case of transfer of personal data to a third country or international organization. You have the right to provide copies of the processed personal data. However, the right to obtain this copy must not adversely affect the rights and freedoms of others.

Right of correction

If, for example, there has been a change of any information or other fact that can be considered personal data on your part, you have the right to request us to correct the processed personal data. In addition, you have the right to supplement incomplete personal data, even by providing an additional statement.

Right of erasure (right to be forgotten)

In certain specified cases, you have the right to require us to delete your personal data or you can also your certain personal data (eg. igc flight logs, image of your glider and your tasks) delete manually in the Lufty app by yourself. Such cases include, for example, that the processed data is no longer needed for the above-mentioned purposes (i.e. you cancel your Subscription). We delete personal data automatically after the necessary period of time, but you can contact us at any time with your request. Your request is then subject to individual assessment (despite your right to deletion, we may have an obligation or a legitimate interest in keeping your personal data) and you will be informed in detail about its processing.

Right to restrictions on processing

We process your personal data only to the extent necessary. However, if you feel that we, for example, have exceeded the above-mentioned purposes for which it processes personal data, you can request that your personal data be processed only for the most necessary legal reasons or that personal data be blocked. Your application is then subject to individual assessment and you will be informed in detail about its processing.

The right to data portability

If you wish us to provide your personal data to another controller, resp. other companies, we will pass on your personal data in the appropriate format to the entity designated by you, unless it is prevented from doing so by any legal or other significant obstacles.

The right to object and automated individual decision-making

If you discover or believe that we are processing personal data in violation of the protection of your private and personal life or in violation of the law (provided that the personal data is processed by the controller in public or is a legitimate interest or is processed for direct marketing purposes, including profiling, or for statistical purposes or for purposes of scientific or historical significance), you can contact us and ask us to explain or eliminate the defective situation.

The right to submit a complaint with the Office for Personal Data Protection

You can at any time turn to your supervisory body, the Office for Personal Data Protection, with its registered office at Lt. Col., with your suggestion or complaint regarding the processing of personal data. Sochora 27, 170 00 Prague 7, website: https://www.uoou.cz/.

Please note that in connection with the above described data subject’s rights there may be limitations or exceptions from applying a right. We will work with you to discuss any possible exceptions or limitations for the case that you wish to exercise the right. If you have any questions about the rights of the data subject or if you want as a data subject to claim to exercise of such rights in connection with the personal data contained in this policy, please contact us via email on privacy@lufty.app

G. SECURITY OF DATA

We are truly aware of the importance and value of personal data and therefore have implemented appropriate organizational and technical measures to ensure the security of your personal data. Personal data is managed and processed in compliance with all applicable legislation, in particular in compliance with GDPR, but also in compliance with the legislation regarding protection of the personality of a natural person. Persons handling personal data are bound by confidentiality and compliance with legal and our internal regulations.

H. CONTACT INFORMATION

If you have any questions or comments regarding the exercise of your rights, this Privacy Policy, or privacy practice of Lufty, at any time you can contact Lufty, address: Lufty.app s.r.o., V závětří 1478/6, Holešovice, Prague 7, Postal Code 170 00, Czech Republic, email:  privacy@lufty.app, telephone: +420 725 546 969

This Privacy Policy becomes effective on 1 April  2020. Lufty is authorized to change this Privacy Policy at any time, whereas a new version shall be published on Lufty ‘s website.