Valqari Privacy Policy

This Policy was last updated on August 3, 2023

Our Privacy Policy explains:

• What information we collect and how.
• Why we collect it.
• How we store, use, and share that information.
• The choices we offer, including how to access and update information.
• How to make an inquiry or complaint if you have concerns about your privacy.

This Privacy Policy applies to information Valqari, LLC and its subsidiaries (“Valqari” “we” or “us”) collect about you when you use our websites, mobile applications and other products and services that link to this Privacy Policy (collectively, the “Services”) and when you contact or otherwise interact with us. For the purposes of this policy, Services include, for example, services we provide in connection with the operation of drones and drone landing sites, including air space-related information and drone traffic and landing planning services (collectively, “Drone Delivery Services”) as well as delivery services provided by affiliates drones and the order information through which those drones operate with a Valqari drone landing station, which will be fulfilled through orders for drone and drone landing station services requested by from us. 

Our Privacy Policy does not apply to the data practices of companies or individuals other than Valqari, including companies you may transact with through our Services or who then use our Services.

INFORMATION WE COLLECT

We collect information you provide to us: 

We collect information you provide directly to us. For example, we collect information when you participate in any interactive features of the Services, fill out a form, provide feedback, participate in a contest or promotion, communicate with us via third party sites, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, delivery information and any other information you choose to provide. For Drone Delivery Services, this may include information you provide about your pilot or organizational license information (such as issue and expiration date and license number), the drone you are operating, your proposed flight destination and plan.

We collect information automatically through the Services:

When you access, use or otherwise interact with our Services, we automatically collect certain information, including:

• Device Information: We collect device-specific information, such as a unique application number (if applicable to the Services you are using), your hardware model, operating system version, unique device identifiers, and mobile network information including phone number.
• Transactional Information: When you request a delivery, we collect information about the transaction, such as the items ordered, merchant details, package details (e.g., type), purchase price, date, delivery destination and other similar order details.
• Log Information: We automatically collect and store certain information in server logs. This includes: details of how you use our Services (including search terms you enter and the results), IP address, and device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
• Device Location Information: Depending on your mobile device and browser settings, we may collect information about the location of the device you use to access our Services, including precise location through our mobile app (in accordance with permission requirements of your mobile device), and your approximate location based on IP address. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers.
• Information about Your Drone and Flights and drone interaction with Valqari drone delivery stations: If you choose to connect your drone to a device while you are using our Drone Delivery Services, we may collect information about your drone, such as your drone’s serial number and model information. We may also collect information about the flight destination you selected, the flight plan generated, your drone’s location, and information about your past flights.
• Cookies and Similar Technologies: We and our service providers use various technologies to collect and store information when you use our Services, and this may include using cookies or similar technologies to identify your browser or device. For example, Valqari uses Google Analytics to understand how visitors engage with our site and apps. 
• Images: Valqari drones and Valqari drone delivery stations may use low-resolution cameras in our navigation systems for safety purposes. The cameras on Valqari’s drones and/or drone delivery stations may incidentally capture low-resolution black-and-white overhead images when fulfilling deliveries, which may include images of individuals or other objects within the field of view of our drones. 
• Information We Collect From Other Sources: We may also obtain information from other sources, third parties, or publicly available data, including as follows:
  • We may collect information about you from our third-party social media channels if you choose to engage with these channels.
  • If you log into our Services through your Google account, we will have access to limited profile data (such as email address, phone number, name and profile picture associated with your Google account).
  • In connection with our Drone Delivery Services, we may collect information, such as delivery address, and details of the products ordered from our partners.
  • In connection with certain Drone Delivery Services, we may collect information about you from:
    • Participating third-party RID services providers. The information we collect from them is similar to the information described above about your drone and flights. If you are located in the US, drone and flight information may be collected from approved UAS Service Suppliers (USS) and Valqari will retain such data until you choose to delete it.
    • Other providers of aviation-related services and their users, such as airspace information about your proposed flight with such provider, in order to detect conflicts.

PAYMENT INFORMATION

If the Services require payment, you may need to provide your credit card information directly to our third party payment processor or through a third party’s website to which the Services link. This information will be governed by the third party’s privacy policy and terms of service.

HOW WE USE INFORMATION WE COLLECT

Valqari may use your data in the following ways:

• Provide, maintain, protect, promote and improve our Services, to develop new ones, and to protect Valqari and our users.
• Help us solve any issues you may have with Valqari or the Services, respond to your comments and questions and provide customer service.
• Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, etc.
• Inform you about our Services, for example, letting you know about upcoming changes, improvements, or for marketing purposes.
• Improve and personalize your user experience and the overall quality and safety of our Services, to improve navigation and to inform the development of new features or Services.
• Monitor and analyze trends, usage and activities in connection with Services.
• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below).
• Comply with any applicable law, regulation, legal process or enforceable governmental request.
• Enforce applicable terms of service, including investigation of potential violations.
• Detect, investigate, prevent, or otherwise address safety, fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Valqari, our users or the public as required or permitted by law.
• Carry out any other purpose described to you at the time the information was collected.

INFORMATION WE SHARE

We do not share personal information with companies, organizations and individuals outside of Valqari unless one of the following circumstances applies (or unless otherwise described in this policy):

• With your consent or at your direction: We will share personal information with companies, organizations or individuals outside of Valqari when we have your consent or if you have directed us to do so. For example, we share information with merchant and delivery partners when you request Drone Delivery Services.
• To related companies in our group: Valqari shares personal information with its subsidiaries, and in more limited instances may share personal information with its affiliates (other companies in our group of companies under common control and ownership).
• With vendors, service providers, advisors and consultants that access information in order to perform services for us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.
• In connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• For legal reasons: We will share personal information with companies, organizations or individuals outside of Valqari if we have a good-faith belief that such disclosure of the information is reasonably necessary to:

                                   -Comply with any applicable law, regulation, legal process or enforceable governmental request.

                                    -Enforce applicable terms of service, including investigation of potential violations.

                                    -Detect, prevent, or otherwise address fraud, security or technical issues.

                                    -Protect against harm to the rights, property or safety of Valqari, our users or the public as required or permitted by law.

                                    –Obtain legal advice.

We also share aggregated or de-identified information that cannot reasonably be used to identify you. For example, we may share this information publicly to show trends about the general use of our Services.

In connection with our Drone Delivery Services, we also share your information as follows:

• When you use the Services to register your drone, authorize your flight, apply for a license or request access to controlled airspace from an aviation or other government authority, we share your information with that government authority, including contact information, information about you or your company (e.g., operator license number), your drone (e.g., registration and serial number), your proposed flight plan (e.g., start time, duration, operation area, and maximum altitude).
• When required to provide or enable similar services. For example, in areas where multiple providers of aviation-related services, including unmanned traffic planning services, are permitted, we will share information about your proposed flight with such service providers in order to detect conflicts.
• If government authorities require that Valqari provide your drone and operator information for remote identification purposes. In jurisdictions where this is required, we will share your information with the applicable government authority or provider authorized by the government authority, such as other remote identification service providers. This information could include your name, contact information, license information, drone serial number and other drone identifiers, your user ID and details of your flight (e.g., location, time and speed). If you are located in the US, this information will be shared with approved UAS Service Suppliers. 

ADVERTISING AND ANALYTICS

We engage others to provide analytics services and serve advertisements across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Valqari and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

ADDITIONAL REGIONAL DISCLOSURE

Retention and deletion of personal data of Australia, EEA, Swiss or British persons.

We retain personal information for different periods of time depending on what it is, how we use it, and how you configure your settings. Some data you can delete or update whenever you like, such as your pilot license in Drone Delivery Services or your address and phone number for delivery services. Other data is deleted or anonymized automatically after a set period of time, such as application usage analytics, which we delete after 420 days. We keep some data until you delete your Valqari Account, such as information about how often you use our services. And some data we retain for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, complying with legal or regulatory requirements or financial record-keeping.

We try to ensure that our Services protect information from accidental or malicious deletion. Because of this, there may be delays between when you delete something and when copies are deleted from our active and backup systems. You can submit a deletion request in the settings of the iOS or Android mobile app or you can contact info@valqari.com.

We also keep information which will help us improve our Services, and conduct further research and product development. We take steps to avoid retaining personal information for only this purpose.

Our legal basis for processing the personal data of EEA, Swiss, or British persons.

If you reside in the European Economic Area (EEA), Switzerland or the UK, certain data protection law applies to the processing of your personal data. We rely on the following legal basis to process your personal data: Where it is necessary to perform our contract with you to provide the Services. Where we have obtained your consent, for example when you opt in to marketing communications from us. You can withdraw your consent at any time, but we may still need to retain a record of your correspondence with us. To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications). 

Where it is necessary for the purposes of our legitimate interests, including:

• Providing, maintaining, and protecting our Services to meet the needs of our users;
• Developing new products and features;
• Communicating with you;
• Detecting, preventing, and otherwise addressing fraud, abuse, security, safety and technical issues with our service;
• Protecting against harm to the rights, property or safety of Valqari, our users or the public as required or permitted by law;
• Performing research that improves our Services for our users and benefits the public;
• Enforcing legal claims, including investigation of potential violations of applicable Terms of Service; and
• Where it is necessary to comply with a legal obligation, for example under anti-money laundering or anti-bribery legislation.

YOUR PRIVACY RIGHTS

Our goal is to be clear about what information we collect, so that you can make meaningful choices about how you interact with our Services. 

We never you use our Services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly. In some circumstances you may alternatively be able to delete it.

We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

You may request access to the information we hold about you or request correction of that information by sending a written request to info@valqari.com. You can also submit a deletion request in the settings of the iOS or Android mobile app.

Subject to certain limitations, if EU data protection law applies to our processing of your personal information, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights and are unable to through the methods described above, you may contact info@valqari.com.

PROCESSING OF INFORMATION IN THE UNITED STATES AND OTHER COUNTRIES

Valqari stores personal information on our servers in multiple countries around the world, including the United States. Data protection laws vary among countries and the laws of some countries may provide a different standard of protection than under the laws of your country. We will take steps designed to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at info@valqari.com.

We work hard to protect Valqari and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:

• We encrypt many of our Services using SSL.
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to personal information to Valqari employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.