We attach great importance to the protection of your personal data. As such, when collecting and processing it, we are guided by these four principles:
- Transparency: we explain what we collect and why we collect it, so that you can make the most well-informed decision possible;
- Security: all the data that you have entrusted to us benefits from strong security;
- Legal guarantees: we respect data protection laws;
- User benefit: when we collect data, it is in order to improve the service and experience we offer, on our Website, in our Software, through our Sales services and our products.
These principles are the foundations on which we wish to grow: in an increasingly connected world, we choose to give our users the widest possible control of their data and to protect the data that is entrusted to us.Our aim is to offer you the best products and the best services.
- GGENERAL INFORMATION
- PROCESSING DATA COLLECTED BY SENSEFLY
- DATA RETENTION AND DELETION
- SHARING PERSONAL DATA WITH THIRD PARTIES
- TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION
- CONTROLLING PERSONAL SHARED WITH SENSEFLY
- PROCEDURES FOR SECURITY AND PROTECTION OF PERSONAL DATA
- MANAGEMENT OF THE PERSONAL DATA OF MINORS
- INFORMATION ON BANKING DATA
- COOKIE INFORMATION
- AMENDMENT OF OUR POLICY
- CONTACT US
APPENDIX 1 – LIST OF PROCESSES UNDERTAKEN BY SENSEFLY
1. GENERAL INFORMATION
senseFly SA, a joint-stock company with capital of CHF 196’815.60, whose head office is located at Route de Genève 38, 1033 Cheseaux-sur-Lausanne, Switzerland registered at the Trade and Companies Registry of the County of Vaud under number CHE-115.246.272 (hereinafter ‘senseFly“, or “we“) is responsible for processing your personal data.
The Laws and Regulations on Personal Data encompass the Swiss Federal Act on Data protection dated June 19th 1992 and the regulation (EU) 2016/679 of 27 April 2016 on the protection of personal data (regulation known as “GDPR”) and any text that might apply them (hereinafter the “Regulations“).
Personal data (hereinafter “Personal Data“) refers to any information relating to an identified or identifiable natural person who may be identified personally, directly or indirectly, in particular by means of an identifier, such as a surname, first name, an identification number, location data or an online username. The data we collect may therefore include your strictly personal data, insofar as it allows you to be identified as a particular person. Conversely, some data does not allow us to identify you directly, such as your profession or your browsing data (the type of browser, terminal and operating system, the path followed on the Website, etc.) but is nevertheless considered as Personal Data because it is attached and/or attributable to the former.
This Policy is an integral part of all our Terms and Conditions (the Website terms and conditions, the Software terms and conditions and the General Terms and Conditions of Sale). By accepting any of our terms and conditions, you expressly accept the provisions of this Policy.
Please read this document carefully in order to be aware of and understand the practices regarding the processing of your Personal Data that we implement and the rights that you are entitled to.
2. PROCESSING DATA COLLECTED BY SENSEFLY
Your consent will be required prior to any collection of your Personal Data. senseFly and its Affiliated companies may exchange such Personal Data and use it in accordance with this Policy. You do not have to give us all of the Personal Data that we ask for. However, if you choose not to share it, access to certain services implemented by our Website and/or our Software may be limited.
Any information that you may have provided to senseFly during your visits to our Website, when using our Software or when purchasing or using our products, is strictly confidential.
The Personal Data collected allows us for instance to implement the Services the Website gives you access to, to keep you posted on our latest product announcements, software updates, and upcoming events. Personal Data are used to help us create, develop, operate, deliver, and improve our products, services, content and our customer communications, and for loss prevention and anti-fraud purposes. Personal Data may be used to verify identity, assist with identification of users and for loss prevention and anti-fraud purposes. From time to time, Personal Data are used to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.
For more information, please consult the table that appears in Appendix 1, summarising how senseFly processes Personal Data through its Website.
2.1. Legal basis for the processing of Personal Data
In accordance with the Regulations, most of the processing referred to in this Policy has received your prior consent.
The primary purpose of this processing is to carry out our contractual obligations in relation to the services offered on/through the Websites and/or the Software. Some of the processing that we carry out can also be dictated by a legal obligation incumbent upon us or based on a legitimate interest such as combating fraud or enabling senseFly’s participation in feedback to the authorities responsible for civil aviation.
2.2. Types of Personal Data collected by senseFly
- Personal Data that you share with us
When you use the Website and/or the Software, you may be required to voluntarily share your Personal Data with us. Here are some examples of the types of Personal Data senseFly may collect:
- creation of a my.senseFly user account via the Website;
- download Software update
- participation in surveys;
- contact of our Customer or Support Service Department.
These Personal Data include the following elements: your surname, first name(s), password, email address, phone number, technical flight data (including geolocation of the drone). The optional nature of the collection of the data is communicated to you.
- Personal Data that senseFly automatically collects
By browsing our Website and/or using our Software and/or activating our Products for the first time, we may automatically collect certain data, including the serial number of your drone when first activated, cookie data, your login details, your browsing data, the type of terminal you use to access or connect to the Website. You will find more details about the technical data that we process in Article 9 “Cookie Information”.
- Personal data that senseFly obtains from third parties
When you are using, through our Products, third-party services (Google Maps™, Airmap™ services, Pix4D™ services, etc.) and/or products (i.e. manufactured by Parrot Drones SAS), the providers of such services and/or products may also collect and process Personal Data through their services (your localisation, your user preferences, your flight data, accompanying services, etc.) independently of the data processing conducted by us.
Please refer to the respective service provider’s, manufacturer’s or any other third party’s privacy information to learn about their own data protection practices.
3. DATA RETENTION AND DELETION
We keep your Personal Data as long as necessary, particularly to fulfil our contractual obligations, comply with our legal obligations or resolve disputes. We retain some of your Personal Data for as long as you have a my.senseFly account.
Upon your request, we will delete or anonymise your Personal Data so that you can no longer be identified, unless the law authorises or compels us to retain certain Personal Data, particularly in the following situations:
- If there is an unresolved issue with your account, such as an outstanding debt or an unresolved claim or litigation, we will retain the necessary Personal Data until the issue is resolved;
- If we are required to retain Personal Data as a result of legal, tax, auditing and accounting obligations, we will retain the necessary Personal Data for the period required by the applicable law; and/or
- If this data is required for our legitimate interests, such as fraud prevention or the security of our users.
In all other circumstances, we will retain your Personal Data for a period that we deem reasonable.
For more information, please consult the table that appears in Appendix 1, summarising how long senseFly retains your Personal Data for processing it via its Website.
4. SHARING PERSONAL DATA WITH THIRD PARTIES
We will not transmit your Personal Data to third parties who may use it for commercial purposes without your express consent.
We may share Personal Data with other Affiliated companies of senseFly within the scope of this Policy. Affiliated companies refer to any company directly or indirectly controlling, controlled by or under common control with, senseFly, such as Parrot Drones SAS or Pix4D.
In accordance with applicable law and with your consent when required, we may aggregate the Personal Data that we receive or send it to our business partners, including any or all of your Data collected via cookies.
We rely on trusted third parties to carry out various operations on our behalf. We can provide them with the information they need to carry out a given service and request that they do not use your Personal Data for any other purposes. We may transfer certain Personal Data to them if it is required for (i) the operation, management, maintenance of our Website; (ii) ensuring that the tasks necessary for the fulfilment of your request/order on the Websites or of a Product (technical services, payment services, verification of identity) are completed; (iii) implementing certain elements of the support and after-sales service; (iv) combating fraud; (v) responding to requests from the authorities.
Your Personal Data may therefore be transferred to a third party when we have a legal obligation to do so or if we believe in good faith that this is necessary to (a) comply with any legal request; (b) comply with any requests from the authorities; (c) in case of emergency involving public health or the physical integrity of a person; (d) in the course of enquiries and investigations; or (e) to secure the rights, property and safety of senseFly and more generally any third party.
5. TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION
We store your Personal Data in servers located in the European Union. However, it is possible that the Personal Data we collect when you use our Websites are transferred to other countries, some of which may have less protective personal data protection legislation than the one in force in the country where you reside. We undertake to take all the measures required to ensure that contractual commitments with these third parties are in accordance with the Regulations. These measures may include checking the standards applied by these third parties for the protection of personal data and security and/or the signing of appropriate contracts (based on the model adopted by the European Commission).
We can use the services of subcontractors located outside the European Union, particularly for responding to your requests for after-sales services and providing us with online payment tools and providing us with commercial and advertising services. This is also the case for senseFly Affiliated companies located outside the European Union to whom we may transfer some of your Personal Data for the purposes of providing our services in those countries.
For more details on the transfer of your Personal Data outside the European Union, please contact us at the following address: firstname.lastname@example.org.
6. CONTROLLING PERSONAL INFORMATION SHARED WITH SENSEFLY
6.1 Rights relating to your Personal Data
In accordance with the Regulations in force, you have a set of rights relating to the Personal Data relevant to you, including:
- A right of access: you can obtain a copy of all your Personal Data processed by senseFly, as well as information about the nature of the processing of your Personal Data.
- A right to rectification: you can obtain the rectification and/or completeness of your inaccurate and/or incomplete Personal Data.
- A right to erasure: you can obtain the erasure of your Personal Data when (i) this Personal Data is no longer necessary for the purposes for which it was collected, (ii) you exercise your right to oppose the processing concerned or (iii) the processing concerned is illicit. However, this right does not apply when it is necessary for senseFly to store your Personal Data to comply with a legal obligation or to exercise rights in court.
- A right to restriction of processing: you can obtain a restriction of processing of your Personal Data when you dispute the accuracy of the data for a period of time that allows senseFly to carry out the appropriate verifications. It is the same when senseFly no longer needs the Personal Data but it is still required by you to defend a right in court, or—when you exercise your right of opposition—for the time required by senseFly to examine your request. When such a restriction is put in place, the Personal Data can only be processed, except for its retention, with your consent or for the defence of a right in court.
- A right to portability: you can obtain the Personal Data that you have provided to senseFly and which is used by senseFly as part of the processing necessary to fulfil your contract, in a structured, commonly used and machine-readable format, and have it transmitted by senseFly to another provider where this is technically possible.
- A right to object: you can request that senseFly, for reasons relating to your particular situation, stops processing your Personal Data in order to pursue its legitimate interests. senseFly will then cease such processing unless it justifies its legitimate and compelling interests over your rights and freedoms.
- A right to define general and specific guidelines defining the manner in which you intend to exercise the above rights after your death.
You also have the right to lodge a complaint with the authority of the country in which your habitual residence is located if you consider that the processing carried out by senseFly violates the provisions of the Regulations. As an example, in Switzerland, the supervisory authority in charge of compliance with personal data obligations is the Préposé Fédéral à la Protection des Données et à la Transparence (PFPDT).
6.2 Procedure for exercising your rights
To exercise your rights over your Personal Data, you can email your request (i) to the address email@example.com or (ii) send it by mail to senseFly SA, Data Protection Officer, Route de Genève 38, 1033 Cheseaux-sur-Lausanne, Switzerland; giving your surname, first name, email address and if possible your customer reference. In accordance with the regulations in force, your application must be signed and accompanied by a photocopy of an identity card bearing your signature and you must provide the address to which we should send you our response.
You also have the right to lodge a complaint with the competent supervisory authority or to obtain compensation from the competent courts if you consider that we have not respected your rights.
7. PROCEDURES FOR SECURITY AND PROTECTION OF PERSONAL DATA
In order to ensure the protection and confidentiality of the Personal Data communicated to us, we use the technical, physical and procedural control measures that are implemented during the collection, processing and transfer of your Personal Data. As such, we have put in place various measures, including pseudonymisation, encryption, access and retention policies.
We also apply security procedures limiting the use and access to your Personal Data on our servers. Only authorised personnel are permitted, in the course of their work, to access your Personal Data.
8. MANAGEMENT OF THE PERSONAL DATA OF MINORS
In accordance with the Regulations, the collection of Personal Data of a child under 16 is permitted only with the valid consent of the person who has parental authority. If you are under the age of 16 and do not have the consent of your parent or legal guardian, please do not provide any Personal Data. If we learn that we have collected the Personal Data of a child under the age of 16 without the valid consent of the parent or legal guardian, we will remove them unless otherwise agreed by the parent or legal guardian.
9. INFORMATION ON BANKING DATA
For the purposes of paying for orders, bank details are collected and kept by our service providers in terms of payment. These comply with the PCI-DSS requirements, an international security standard whose objectives are to ensure the confidentiality and integrity of cardholder data, and thus secure the protection of card and transaction data.
10. COOKIE INFORMATION
This section allows you to better understand how cookies work and how to use current tools to configure them.
10.1. What is a cookie?
A cookie is a small text file placed on your terminal when visiting a Website or looking at an advertisement. Their purpose is to collect information about your browsing or to ensure the consistency of browsing from one page to another on the Website and also to send you personalised services.
On your terminal, cookies are managed by your internet browser.
10.2. The different issuers of cookies
- senseFly cookies
These are cookies deposited by senseFly on your terminal to meet requirements for browsing, optimisation and customisation of the services on our Website.
- Cookies from third parties
These are cookies deposited by senseFly partner companies but may also be deposited when you click on banner ads on our Website.
These are cookies deposited by third-party companies (for example advertising agencies or partners) to identify your interests through the products you look at or purchase on our Website and customise the advertising offer provided to you on our Website or outside our Website. They can be deposited while you are browsing our Website or when you click in the advertising spaces of our Websites. The data transmitted by these cookies is anonymous and no personalised data is transferred. We do not control the cookies placed outside the senseFly Website by the advertising agencies that act on their own behalf.
In the context of advertising partnerships, we may send partners who act on our behalf data concerning your purchases and the products consulted on our Website. We make sure that the partner companies (i) agree to treat the information collected on our Website exclusively for the purposes of senseFly and in accordance with our instructions, in accordance with the Regulations in force; and (ii) undertake to implement appropriate measures to secure and protect the confidentiality of Personal Data.
10.3. The cookies used
- Strictly necessary cookies
These are mainly cookies deposited by senseFly.
- Analytical cookies
These cookies provide us with information about the use and performance of our Website and improve its operation (for example, finding out the most frequently viewed pages of our Website).
These are mainly cookies deposited by senseFly.
- Functional cookies
These cookies allow us to personalise your experience on our Website (for example reminding you of the most recent products you consulted). They also allow you to benefit from our personalised advice and promotional offers according to the origin of your browsing (for example if you come from our partner Website). They can also be used to provide you with features that you have requested (for example, my favourite store or my personalised advice).
- Advertising cookies
These are cookies used to present advertisements to you or to send you information adapted to your interests on our Website or outside our Website when browsing the Internet. They are used to limit the number of times you see an advertisement and help measure the effectiveness of an advertising campaign.
The refusal of these advertising cookies has no impact on the use of our Website. However, refusing advertising cookies will not stop advertising on our Website or on the Internet.
It will only result in an advertisement that does not reflect your interests or preferences being displayed.
These cookies are mainly third-party cookies.
- Social media cookies and plug-ins (social media buttons)
These social media cookies are intended to allow users to share pages and content via third-party social media sites. They also make it possible to target the advertising offer on social media sites.
Our Website also uses social media plug-ins or buttons.
Social media plug-ins make it easier to share the pages and contents of our Website on various social media platforms. They allow you, for example, to like and share information from our Website with your friends on social media sites.
Please ensure you read the privacy policies of the various social media sites to understand the purpose of using the browsing information they can collect through the social media buttons on our Website. These protection policies must enable you to exercise your choices with these social media sites, in particular by setting up your usage accounts for each of these sites.
10.4. Accepting or refusing cookies
You have different ways available to you to manage cookies.
- Configuring your internet browser
If your browser is configured to refuse all cookies, you will not be able to take advantage of essential features of our Website, such as receiving personalised recommendations. In order to manage cookies as close as possible to your expectations, we invite you to configure your browser, taking into account the purpose of cookies described above.
Here’s how to control or prevent the registration of cookies:
Every browser is configured differently. It is described in the help menu of your browser, which tells you how to change your cookie options.
You can disable cookies by following the links below:
- Internet Explorer™: http://windows.microsoft.com/fr-FR/windows-vista/Block-or-allow-cookies
- Safari™: http://docs.info.apple.com/article.html?path=Safari/3.0/fr/9277.html
- Chrome™: http://support.google.com/chrome/bin/answer.py?hl=fr&hlrm=en&answer=95647
- Firefox™: https://support.mozilla.org/fr/kb/Activer%20et%20d%C3%A9sactiver%20les%20cookies
- Opera™: http://help.opera.com/Windows/10.20/fr/cookies.html
- Settings on a platform for managing cookies
You can manage your cookies by visiting cookie management platforms offered by advertising professionals.
For more information about cookies, please consult the Website of the supervisory authority in your country.
11. AMENDMENT OF OUR POLICY
It may be the case that we have to make changes to this Policy. When this is required, we will notify you in an appropriate manner, for example, by posting a message on the Website. We advise you to regularly consult the page dedicated to the collection and processing of Personal Data on the Website to be aware of any changes or updates to our Policy.
12. CONTACT US
If you have any questions relating to this Policy or any requests relating to your Personal Data and/or you wish to exercise your rights, you can contact us (i) via the following address: firstname.lastname@example.org; or (ii) by post to senseFly Data Protection Officer, Route de Genève 38, 1033 Cheseaux-sur-Lausanne, Switzerland. In accordance with the regulations in force, your application must be signed and accompanied by a photocopy of an identity card bearing your signature and you must provide the address to which we should send you our response.
|APPENDIX 1 – LIST OF PROCESSES UNDERTAKEN BY SENSEFLY|
THE PURPOSES FOR WHICH WE COLLECT AND PROCESS PERSONAL DATA ARE:
WE ARE LAWFULLY PERMITTED TO USE YOUR PERSONAL DATA FOR THIS PURPOSE BECAUSE:
THE PERSONAL DATA WE USE ARE:
WE RETAIN YOUR PERSONAL DATA DURING:
|Order Fulfillment (Process and ship, online order management, deliver or service your orders, inform you about the status of your order, conduct identity verification, comply with export control regulations, prevent fraud and money laundering and other fraud detection activities, recover any debts owed to us, reach security purposes)||Fulfilling contractual obligations (It is necessary to enable us to perform our contractual commitments to you) Our legitimate interest (It is necessary in our legitimate interest to serve our customer properly, provide you with a personalized service and protect our business and assets) Legal obligations (It is necessary to comply with legal requirements: request from a competent law enforcement agency, control export compliance, protection of our rights, privacy, safety or property or protection of the public, enforcement of the terms of any of our agreements or the terms of our website)||Personal contact information (any information you provide to us that would allow us to contact you such as your name, postal address, e-mail address, phone number) Payment and financial information (any information that we or the payment platform – i.e Paypal – need(s) to fulfil an order or that you use to make a purchase)||2 years from the last contact with customer or deletion upon request 10 years with regards to billing information|
|Customer service (Answer your enquiry e.g. order status, technical or product questions, general question)||Fulfilling contractual obligations (It is necessary to enable us to perform our contractual commitments to you) With your consent (to answer your request)||Personal contact information (any information you provide to us that would allow us to contact you such as your name, postal address, e-mail address, , phone number, account login information)||5 years from the last contact or ticket closing with the concerned service|
|Support Service to customers (Technical support, issues, complaint, products awareness, training materials, markets research, statistics)||Fulfilling contractual obligations (It is necessary to enable us to perform our contractual commitments to you) Legitimate interest (It is necessary in our legitimate interest to improve and develop new products and services, be more efficient) Legal obligations (It is necessary to comply with legal requirements: request from a competent law enforcement agency, control export compliance, protection of our rights, privacy, safety or property or protection of the public, enforcement of the terms of any of our agreements or the terms of our website) To manage safety recalls and quality campaigns||Personal contact information (any information you provide to us that would allow us to contact you such as your name, postal address, e-mail address, phone number, account login information)||Personal information belonging to any individual are replaced by the information of the company as customer 5 years from the ticket closing with the concerned service|
|Newsletters, Waypoint blog, senseFly Academy, contests, marketing and other promotions (Provide you with information about goods and services through marketing communication or campaigns or promotions via emails, ads, phone calls, postal mailings)||With your consent (To answer your request: e.g. subscription to our newsletters, provision of your business card, etc.)||Personal contact information (any information you provide to us that would allow us to contact you such as your name, postal address, e-mail address, social network details, phone number) Demographic information and interests (any information that describes your demographic or behavioral characteristics, favorite products, business) Customer generated content (any content that you create and then share with us on third party social network or by uploading it to one of our websites such as photos, videos, personal stories or other similar media or content)||Deletion/subscription upon request|
|Training services (Training sessions, materials and contents, senseFly Academy)||Fulfilling contractual obligations (It is necessary to enable us to perform our contractual commitments to you)||Personal contact information (any information you provide to us that would allow us to contact you such as your name, postal address, e-mail address, social network details, phone number)
Payment and financial information (any information that we or the payment platform – i.e Paypal – need(s) to fulfil an order or that you use to make a purchase)
|4 years from product’s end of life 10 years with regards to billing information|