PRIVACY POLICY

PRIVACY POLICY
Last Updated Aug 2019

This Privacy Policy is incorporated by reference into the S61C™ Terms of Use and End User License Agreement (“EULA”). The terms “S61C,” “we,” and “us” include S61C Platform its parent company Orlando O Spencer I, Inc.  and its affiliates. The Privacy Policy explains how S61C may collect, use, and disclose information we obtain through the “Service.” Any capitalized terms used and not defined in this Privacy Policy shall have the meaning given to them in the EULA.

IMPORTANT NOTE: By accessing or using the Service, you expressly consent to S61C’s collection, use, and disclosure of your Personal Information in accordance with the terms and conditions of this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the EULA.

Categories of Personal Data Processed by S61C

PERSONAL DATA THAT IS PROCESSED WHEN YOU CREATE A S61C ACCOUNT: When you create a S61C account, we ask you to provide your email address and name. PURPOSES AND LEGAL GROUNDS:
  1. S61C processes your email address because you use your email address and your password to sign in to your account. The legal ground for processing your email address for this purpose is based on S61C’s legitimate interest in protecting the security of your account.
  2. S61C also processes your email address for the purpose of sending you important information about your S61C products, apps or account, such as important safety information or material changes to this Privacy Policy. The name you provide is associated with your account profile. The legal ground for processing your email address and name for these purposes is S61C’s legitimate interest in providing you important safety or other information about your S61C products, apps or account or material changes to this Privacy Policy.
  3. For EU citizens, if you provide your opt-in consent to receiving marketing information from S61C, S61C will also process your email address for the purpose of sending you marketing information about S61C products and apps, newsletters, and other occasional emails. For non-EU citizens, by giving S61C your email address, you consent to receiving marketing information from S61C and S61C will also process your email address for the purpose of sending you marketing information about S61C products and apps, newsletters, and other occasional emails. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your S61C account or through the unsubscribe link at the bottom of our marketing emails. The marketing emails you receive from S61C are based on the preferences you provide in your S61C account, the locale indicated by your Internet Protocol (IP) address, the types of S61C devices you have added to your S61C account, and any subscriptions included in your S61C account. The legal ground for processing this data for this purpose is S61C’s legitimate interest in reducing the number of marketing emails sent to each particular customer by selecting which customers receive a particular marketing email rather than sending every marketing email to every customer who has consented to receiving marketing emails.
  4. S61C also processes your email address to associate it with your S61C account when you interact with our customer support representatives. The legal ground for this processing is our legitimate interest in providing quality customer support.

PERSONAL DATA THAT IS PROCESSED WHEN YOU MAKE A PAYMENT:

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

PURPOSES AND LEGAL GROUNDS:

The legal ground for processing this data for these purposes is performance of a contract. We also process your personal data as part of our fraud detection processes. The legal ground for processing your personal data for that purpose is our legitimate interest in protecting S61C and our customers from attempts to engage in fraudulent transactions. Your financial account information, such as your credit card, is required to make a payment for a product. The legal ground for processing your email address for this purpose is based on S61C’s legitimate interest in collecting payment for its services.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE S61C TO CREATE AND FILE FLIGHT PLANS:

You can use S61C to create flight plans and file those flight plans with applicable aviation authorities. When you do this, we process your name and address, aircraft details, date and time of the flight, and associated flight details.

PURPOSES AND LEGAL GROUNDS:

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

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

When you use S61C, we process the destination, estimated time enroute, and associated travel details. Without location information, S61C preflight and CFI-Student activities alert features will not function properly. This data is uploaded to your S61C account.

PURPOSES AND LEGAL GROUNDS:

This information is processed to help you keep track of important details regarding your training activities. The legal ground for processing this information is our legitimate interest in providing a tool to our customers to keep track of important training details. In addition, S61C’s training activities features help provide you save time and money.

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE THE ASSIGNMENT and QUIZ FEATURE:

When you use the assignment an quiz feature on S61C, we process information about your answers, on each question of a quiz and when are here you are completed an assignment, and store all the result of your assignment and quiz in your account and the account of you chosen certificated flight Instructor ( “CFI”). If a CFI is no logo your choose CFI they will no longer have access to you assignment and quiz data. By choosing a CFI you agree to share information about your assignments and quizzes with that specific CFI.

PURPOSES AND LEGAL GROUNDS:

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

PERSONAL DATA THAT IS PROCESSED WHEN YOU USE THE APPLICATION:

When you use the S61C app, we process information about you and your device including a device ID, IP address, mobile software and hardware information, pages or areas visited within the Service, what time said pages and areas are visited, and web browser information, so that we can provide and customize functionality, such as push notifications. You may also permit the Service to access your device’s contact list and photo storage. We may share information about your psychographics learning profile   and training  information to ground school vendors, CFIs and other third party service provider.

PURPOSES AND LEGAL GROUNDS:

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

PERSONAL DATA THAT IS PROCESSED WHEN YOU COMMUNICATE WITH S61C:

When you interact with our customer support representatives via email, telephone, or online, we collect personal data, such as your name, mailing address, phone number, email address, and contact preferences; and information about the S61C products you own. We also may create event logs that are useful in diagnosing product or app performance-related issues, and capture information relating to the support or service issue. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyze any feedback provided to us through voluntary customer surveys.

PURPOSES AND LEGAL GROUNDS:

We use this information to provide you with customer and product support and to monitor the quality and types of customer and product support we provide to our customers. The legal ground for processing this information for these purposes is S61C’s legitimate interests in providing quality product support.

PERSONAL DATA THAT IS PROCESSED WHEN YOU VISIT THE S61C CAREERS PAGE:

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

PURPOSES AND LEGAL GROUNDS:

We use this information to evaluate you for a career at S61C. The legal ground for processing this information for the purposes is S61C’s legitimate interest in hiring qualified candidates.

Categories of Recipients of Personal Data

OTHER SERVICE PROVIDERS:

S61C uses cloud services from third parties such as Trilio  and SendGrid, to assist in sending emails and to analyze the use and performance of S61C products. Those services track the activities associated with emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. S61C uses this data to analyze the level of engagement with its emails. S61C uses third-party service providers to help us better understand usage of the S61C website and the S61C app.

OTHER DISCLOSURES:

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

Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of S61C assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information, and we disclaim any liability arising out of such entity’s failure to comply with the terms of the EULA or this Privacy Policy.

Cookies and Similar Technologies

WEBSITE:

To help analyze how you and other visitors navigate the S61C websites, we compile aggregate statistics about site usage and response rates to help diagnose any problems with S61C’s servers, administer the S61C websites, and maintain user experience continuity across website pages and site visits, we, with assistance from third-party analytics service providers, collect certain information when you visit our site. This information includes IP address, geographic location of the device, browser type, browser language, date and time of your request, time(s) of your visit(s), page views and page elements (e.g., links) that you click. We may use cookies, pixel tags, web beacons, clear GIFs or other similar tools on our sites or in our email messages to assist us in collecting and analyzing such information. We use this information to provide better, more relevant content on our sites, to identify and fix problems, and to improve your overall experience on our sites. If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to be given the choice of declining or accepting them. If you reside in the European Union or other jurisdiction that requires us to obtain your consent to use cookies on our sites, then you will have an opportunity to manage your cookie preferences on the sites; except that certain cookies are required to enable core site functionality, and you cannot choose to disable those cookies.

S61C APP:

We also collect data from users about their usage of the S61C app. The types of analytical information that are collected include the date and time the app accesses our servers, app version, the location of the device, language setting, what information and files have been downloaded to the app, user behavior (e.g., features used, frequency of use), device state information, device model, hardware and operating system information, and information relating to how the app functions. S61C uses this data to improve the quality and functionality of the S61C app; to develop and market products and features that best serve you and other users; and to help identify and fix app stability issues and other usability problems as quickly as possible. The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products, apps, and websites so we can enhance the user experience and functionality of our products, apps, and websites. Here are examples of third-party providers of analytics and similar services we currently use:

Information Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Neither S61C, nor its parent company, nor its affiliates, nor any of their respective employees, officers or agents or the provider of the internet services on behalf of S61C (nor any other person involved in the management or establishment of the Service) can give any representation or warranty as to the absolute security of the data transmitted using the Service, and cannot give any guarantee that such data will not be compromised by bad actors. If you choose to provide data to or allow collection of data by S61C, then you do so understanding the aforementioned risk. By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice by mail.

Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at radio@S61C.com. If we learn that we have collected any Personal Information from children under 13 in a manner that is inconsistent with the U.S. Children’s Online Privacy Protection Act, we will promptly take steps to delete such information and terminate the child’s account as soon as practicable.

Marketing

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

Legal and Similar Disclosures

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

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products and apps, as we improve our current offerings and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the S61C website and through the S61C app.

Retention of Personal Data

We will retain your personal data as long as your S61C account is active. In addition, see below under “Your Rights” for a description of your right of erasure.

Data Controller and Data Protection Officer

The personal data collected by S61C is controlled by S61C’s Data Protection Officer at 5694 Mission Center Rd, Suite 602-327, San Diego, CA 92108, which you can also contact by email at radioS61C.com.

Your Rights

If you reside in the European Union, you have the right under the General Data Protection Regulation to request from S61C access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to processing of your personal data, and the right to lodge a complaint with a supervisory authority. If you reside outside of the European Union, you may have similar rights under your local laws. To request access to or rectification, portability or erasure of your personal data, or to delete your S61C account, email radio@S61C.com If you live in the European Union and you wish to exercise your right to restriction of processing or your right to object to processing, contact S61C’s Data Protection Officer at 5694 Mission Center Rd, Suite 602-327, San Diego, CA 92108, which you can also contact by email at radio@S61C.com. If you do not live in the European Union but you believe you have a right to restriction of processing or a right to object to processing under your local laws, please contact S61C at privacy@S61C.com.