Last updated: January 29, 2024
1. Introduction
Welcome to FlyCode Inc
FlyCode Inc (“FlyCode”, “us”, “we”, or “our”) operates https://www.flycode.com/
Our Privacy Policy governs your use of our Service, and explains how we collect, safeguard and disclose information that results from your use of our Service.
By using Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes youragreement with us (“agreement”).
2. Definitions
SERVICE means the https://www.flycode.com/ website operated by FlyCode Inc and any services offered through the website or through engagement with Flycode.
PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit). (See additional explanation under Section 4 below)
COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively. DATA SUBJECT is any living individual who is the subject of Personal Data.
3. The categories of personal data FlyCode collects:
(i) .User Data: personal data concerning our Customers’ internal focal persons who directly engage with FlyCode concerning their organizational account, and users of the platform on behalf of such Customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Customer (collectively, “users”); as well as the Customer’s business needs and preferences, as identified to us or recognized through our engagement with them.
(ii) Prospect Data: personal data relating to visitors of our websites, participants at our events, and any other prospective customer, user or partner (collectively, “prospects”) who visits or otherwise interacts with our website, online ads and content, emails, sales and marketing channels, integrations or communications under our control (i.e. the “Service”).
If you are a User or Prospect, please read this Privacy Policy carefully and make sure that you fully understand it.
Our Service is designed for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Service.
In rare circumstances, part of a code that our Customers have engaging with the Service may include minimal personal data, which in such an event we will process on behalf of that respective Customer. This Privacy Policy (which describes FlyCode’s own privacy and data processing practices) does not apply to such processing done on our Customers’ behalf. To learn about the privacy policy and practices of our Customers, please contact them directly
4. Types of Data Collected
Personal Data
While using our Service, we may collect certain Personal Data about you which may include, but is not limited to:
(a) Business email address
(b) First name and last name
(c) Company and position information
(d) Phone number
(e) Address, State, Province, ZIP/Postal code, City
(f) Usage Data
(g) Location Data
Usage Data
Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. Some of this is achieved through the use of Cookies and data collection technologies. See more on Cookies below. Cookies and Data Collection Technologies We and our Service Providers use cookies, anonymous identifiers, pixels, container tags and similar technologies to provide our Service, ensure the Service performance, and analyze the activity on our Service. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other technologies are also used such as beacons, tags and scripts to collect and keep information to improve and analyze our Service. Some cookies are removed when you close your browser tab or window. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
You can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Service.
We also use the web analytics tool Google Analytics. This tool helps us understand users’ behaviour on our Service, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service provider is available at: www.google.com/policies/privacy/partners. Further information about your option to opt-out of this analytics service is available at: https://tools.google.com/dlpage/gaoptout.
Examples of Cookies we use:
(a) Session Cookies: We use Session Cookies to operate our Service.
(b) Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
(c) Security Cookies: We use Security Cookies for security purposes.
(d) Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
To learn more about our practices concerning cookies and tracking, please see our Cookie settings popup. For more information on our cookie and data collection technologies practices, you may also use the “Cookie settings” feature available in our Service depending on your location and activity on our Service, as applicable.
5. Use of Data
FlyCode Inc uses the collected data for various purposes and based on the ensuing lawful bases:
(a) to provide and maintain our Service; (Performance of a Contract (to the extent applicable); Legitimate Interest).
(b) to notify you about changes to our Service; (Performance of a Contract (to the extent applicable); Legitimate Interest).
(c) to allow you to participate in interactive features of our Service when you choose to do so; (Performance of a Contract
(to the extent applicable; Consent (to the extent applicable).
(d) to provide customer support; (Performance of a Contract (to the extent applicable); Legitimate Interest)
(e) to gather analysis or valuable information so that we can improve our Service; (Legitimate Interest).
(f) to monitor and analyze the usage of our Service; (Legitimate Interest).
(g) to detect, prevent and address technical issues; to support and enhance our data security measures, including for purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity. (Performance of a Contract (to the extent applicable); Legitimate Interest, Compliance with legal obligations).
(h) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; (Performance of a Contract (to the extent applicable); Legitimate Interest; Compliance with legal obligations)
(i) to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.; (Performance of a Contract (to the extent applicable); Legitimate Interest; Compliance with legal obligations)
(j) to provide you with news, special offers and general information about other goods, services and events, contests and promotions which we offer; you may always opt not to receive such information; (Performance of a Contract (to the extent applicable); Consent (to the extent applicable)).
(k) To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose; (Performance of a Contract; Legitimate Interest) for any other purpose with your consent, collected in accordance with applicable laws, as necessary.
(l) To comply with applicable laws and regulations; (Compliance with legal obligations)
(m) To comply with court orders and warrants, and prevent misuse of the Service, and to take any action in any related legal dispute and proceeding; (Performance of a Contract; Compliance with legal obligations; Legitimate interest)
If you reside or are using the Service in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Service, or due to nature of such processing) (“Consent”), your acceptance of our Terms and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@flycode.com
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
6. Data localization
We and our authorized Service Providers (as defined below) maintain, store and process personal data in Israel and other locations, as reasonably necessary for the proper performance and delivery of the Service, or as may be required by law.
While privacy laws may vary between jurisdictions, FlyCode is committed to protecting personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
FlyCode is headquartered in Israel, a jurisdiction which is considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to be offering an adequate level of protection for the personal data originating from the EEA, Switzerland and the UK, respectively. We transfer personal data from the EEA, Switzerland and the UK to Israel on this basis. For data transfers from the EEA, Switzerland or the UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO). You can obtain a copy by contacting us as indicated in Section 19 below.
Moreover, FlyCode will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data.
7. Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.
If you have any questions about our data retention policy, please contact us by e-mail at privacy@flycode.com
8. Communications
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use of some of our Service (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our user or prospect, subject to any necessary collection of your consent as appropriate based on applicable laws. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an e-mail to: Privacy@flycode.com, changing your communications preferences in your profile settings whilst being logged as a user to our Service (when the feature is available), or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
9. Disclosure of Data
We may disclose personal data in the following ways:
(a) Disclosure for Legal Compliance.
We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
(b) Business Transactions, Affiliates and Subsidiaries.
We may share personal data internally within our group, for the purposes described in this Policy. In addition, should FlyCode or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
(c) Sharing your Feedback or Recommendations.
; If you submit a public review or feedback, note that we may (at our discretion) store and present your review on the Service. If you wish to remove your public review, please contact us at privacy@flycode.com
(d) Protecting Right and Safety.
We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of FlyCode and our employees, any of our Visitors or Users, or any members of the general public.
(e) Event Sponsors.
If you attend an event or webinar organized by us, or download or access an asset on the Website related to such an event, webinar or other activity involving third party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may be asked to consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will also be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned;
(f) Service Providers.
We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial, privacy and compliance advisors (collectively, “service providers“). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use the data as determined in our agreements with them.
(g) Third-Parties.
We may engage selected business and channel partners, resellers, distributors and providers of professional services related to our Service, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our users and prospects. In such instances, we may share relevant contact, business and usage details with the respective third-party, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of these third-parties, please note that any aspect of that engagement which is not directly related to the Service and directed by FlyCode is beyond the scope of FlyCode’s Terms and Privacy Policy, and may therefore be covered by that third-party’s own terms and policies.
For the avoidance of doubt, FlyCode may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
10. Security of Data
We implement industry-standard physical, procedural and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security
11. Your Data Protection Rights
In certain circumstances, you may have the following data protection rights:
(a) the right to access, update or to delete the information we have on you;
(b) the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
(c) the right to object. You have the right to object to our processing of your Personal Data
(d) the right of restriction. You have the right to request that we restrict the processing of your personal information;
(e) the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
(f) the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
Please note that when you ask us to exercise any of your rights under this Privacy Policy or applicable law, we may need to ask you to provide us with certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data regarding which you request to exercise your rights. Such additional data may be then retained by us for legal, compliance and auditing purposes (e.g., as proof of the identity of the person submitting the request or proof of request fulfillment). We may redact from the data which we will make available to you, any personal data related to others. Please also note, we may not able to provide Service without some necessary data.
To request to exercise your rights please email us at fly@flycode.com.
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj.
You may also have the right to lodge a complaint with the relevant Data Protection Authority about our collection and use of your Personal Data. If you are a resident of the EU, , please contact your local data protection authority in the European Economic Area (EEA) for more information.
12. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
(a) users can visit our site anonymously;
(b) our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
(c) users will be notified of any privacy policy changes on our Privacy Policy Page;
(d) users are able to change their personal information by emailing us at Privacy@flycode.com.
Our Policy on “Do Not Track” Signals:
We honour Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
13. California Requirements
This policy describes the categories of personal information we may collect and the sources of such information (in Section 3 above), and our retention (Section 7) and deletion rights (Section 10) practices. We also included information about how we may process your information (in Sections 4 through 9), which includes for “business purposes” under the California Consumer Privacy Act (CCPA). We do not sell your personal information for the intents and purposes of CCPA. We may disclose personal data to third parties or allow them to collect personal data from our Service as described in Section 8 above, if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal data, or if you integrate the services of third parties with our Service, or direct us to disclose your personal data to third parties, or as otherwise described in Section 8 above.
If you have any questions or would like to exercise your rights under the CCPA, you can contact privacy@flycode.com
14. Data Controller/ Processor
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
FlyCode is the “data controller” of Prospect Data. With respect to such data, we assume the responsibilities of data controller (to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our service providers processing such data will assume the role of “data processor”.
FlyCode is both a “data controller” and “data processor” of User Data. Such data is processed by FlyCode for its own purposes (as described in Section 5 above), as an independent ‘controller’.
In rare circumstances, part of the code that our Customers have engaging with the Service may include minimal personal data, which in such an event we will process on behalf of our Customers as a “data processor” of such personal data. Accordingly, FlyCode processes Customers’ personal data strictly in accordance with our Customers’ reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such Customers. In such instances, our service providers who process such Customer personal data on our behalf are the “sub-processors” of such personal data. Our Customers are solely responsible for determining whether and how they wish to use our Service, and for ensuring that all individuals using the Service on their behalf, as well as all individuals whose personal data may be included in the code engaging with the Service have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of personal data through our Service are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, submitted by their users and other individuals whose data they process through the Service.
15. Links to Other Sites
Our Service may contain links to other sites or services that are not operated by us. We are not responsible for the privacy practices of these third parties. We strongly advise you to review the Privacy Policy of every third party when you leave our Service. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. This Privacy Policy applies only to the Service.
16. Children's Privacy
Our Service is not intended for use by or to attract children (i.e. individuals considered minors under applicable law).
We do not knowingly collect personally identifiable information from minors. If you become aware that a minor has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from minors we will promptly take steps to remove that information from our servers.
17. Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any substantial changes by posting the new Privacy Policy on our Service.
We will let you know via email and/or a prominent notice on our Service, prior to the substantial change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
18. Contact Us
If you have any questions about this Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact us: By email: Privacy@flycode.com.
