myPlane’s Privacy Policy

Last updated: 10th of February, 2022

This privacy policy (“Privacy Policy“) serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use of website myplane.io and its subdomains (“Site“), and software, content, and other services (all of the foregoing collectively, “Services“) owned, controlled or offered, directly or indirectly, by myPlane Ltd a company incorporated and registered in Finland with company number 3165532-5, or our affiliates (“myPlane“, “we,” “our” or “us“). Users, account holders, customers, visitors, and others who download, access, use and/or subscribe to our Services (“you“) agree to our Privacy Policy.

You expressly understand and acknowledge that this Privacy Policy shall apply to Site, but myPlane service, as available at platform.myplane.io, shall be governed by a separate data processing agreement entered between registered users and myPlane.

PLEASE DO NOT ACCESS OR USE OUR SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

1. Information

Personal Information

“Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, geographic location of your computer or mobile device, telephone number, email address and credit card information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

We may collect Personal Information from you when you (i) use or visit our Sites, (ii) register for Services or create an account or profile (“Account”), (iii) access Services through social networking sites or third party services, (iv) subscribe to newsletters; (v) send invites to join Services, “share” Services social networking sites or perform other similar features; (vi) request technical support; and (vii) otherwise use our online Services where Personal Information is required for such use and/or participation. Personal Information we collect will vary depending upon Services you use and may include your name, email address, phone number, birth date, mobile phone number and location.

We may use, depending on Services, (i) location based on the IP address presented by you, and/or (ii) network-based geo-location data based on proximity of network towers or the location of Wi-Fi networks.

In this Privacy Policy, we refer to all information collected from or about you, including Personal Information and non-Personal Information, as well as any rating related information, payment related information and all data in our Service about you, as “Your Information.”

Automatically Collected Information

We will also collect certain pieces of information automatically and passively in order to provide the Services. In addition, we and other third parties use cookies and other technologies to passively collect non-Personal Information as described. The information collected typically includes browser, mobile device, such as model, device IDs or other device identifiers, operating system or platform type, IP Address (as defined below), devise language and time zone, network Media Access Control (MAC) address and connection, referring site, and access date and time. When you download and use Services, information such as usage information, including without limitation username, app features or pages viewed, debug logs and other system activities will be tracked and communicated back to a centralized server. myPlane collects this data to best serve its users.

Cookies and Other Technologies

A “cookie” is a small text file that is stored on your browser or device by websites, apps, and online media that are used to remember your browser or device during and across website visits or sessions for purposes of functionality and preferences. Cookies do not enable anyone to access personally identifiable information that you have not already given us. We also use cookies to deliver content specific to your interest and to monitor Site or mobile app usage. Such practices are subject to the terms and privacy policies of such companies. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the Services.

We and our service providers may also use “pixel tags,” “web beacons,” “clear GIFs,” or similar means in connection with the Services and HTML-formatted email messages to, among other things, track the actions of users, to determine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates. Our third-party partners may use a “pixel tag” to collect anonymous information about your visits to the Sites and to other websites. This information is collected anonymously, in a manner that does not personally identify you.

IP Address

When you visit and interact with Sites, we and/or third parties with whom we have contracted to provide services to us may collect your Internet Protocol Address (“IP Address“), which is a number that is automatically assigned to the computer that you are using by your internet service provider. This number is identified and logged automatically in our server log files whenever you visit Sites, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP Addresses to monitor the regions from which Users navigate the Sites and for fraud prevention purposes.

Do Not Track

If you disable cookies or activate “do not track” signals or other mechanisms in your browser, you may lose some or all of the features and functionalities of Services.

2. Use of Collected Information

myPlane believes that the privacy of its users is paramount and strives to use their data only in ways outlined in this Privacy Policy. By providing your information to us, you are expressly and voluntarily accepting and consenting to our processing of Your Information as set forth in this Privacy Policy. Supplying to us any information deemed “sensitive” by applicable law, in the phase where you have registered into the platform, is entirely voluntary on your part. Most uses of the collected data are for internal purposes only.

When you submit information to us, it is collected, processed and maintained solely by us or by third party service providers or subcontractors who are bound by privacy restrictions at least as restrictive as those set forth in this Privacy Policy. Your Information is used and disclosed for, but is not limited to, the following purposes: (i) to provide Services, including without limitation to collect and remit payment for paid features, (ii) to administer your use of Services and any Accounts you may have with us, (iii) to personalize your experience, (iv) to provide to you Service announcements or inform you of new releases and features, (v) to provide you with further information and offers from us or third parties that we believe you may find useful or interesting, such as newsletters, marketing or promotional materials, (vi) to perform tasks on behalf of and according to instructions of a third party, such as payment processors or third-party service providers (vii) to resolve any disputes between users of Sites or between such users and us, (viii) to contact you to obtain feedback from you regarding Site and Services, and (ix) and to make, modify and combine various rating type of analyzes within our Services at our discretion. If you decide at any time that you no longer wish to receive such contact, announcements, information or offers, please follow the unsubscribe instructions provided in the communication.

We use non-Personal Information for the above purposes and in addition in order to (i) monitor and analyze use of Services and for the technical administration of Sites, (ii) improve our Sites and Services, (iii) generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users, and (iv) verify that users of Services meet the criteria required to process their requests.

Service Providers and Location of your Information

myPlane may engage certain service providers for additional features, such as payment processing, hosting, providing analytics, and helping us deliver and develop the Services. myPlane will thoroughly examine the privacy policies of partners to ensure that its users’ data is safe and taken care of responsibly. Third parties will not be able to use your information in ways that are prohibited by this Privacy Policy. However, myPlane is not responsible for the privacy policies and/or practices of such third parties.

Upon using service providers, Your Information can also be transferred  to countries outside the European Economic Area and in such case myPlane has appropriate safeguards in place by using standard data protection clauses approved by the European Commission.

Analytics Information

We may use also third-party analytics tools to help us measure traffic and usage trends for Services. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add-ons, and other information that assists us in improving Services. We may collect and use this analytics information together with your Personal Information and non-Personal Information and stitch together session data from unauthenticated user visits with authenticated user visits to build a broader profile of our individual users so that we can serve you better.

Corporate Transactions

myPlane may disclose certain information in the event that it is merged, acquired, sold, or some of its assets are acquired. In such case myPlane will endeavor to ensure that (i) the entity who receives your information treats it in accordance with this Privacy Policy, (ii) all applicable personal data legislation will be complied with and (iii) appropriate notices are made to data subjects in good time.

Compliance with Law and Law Enforcement

We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (i) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (ii) enforce Privacy Policy; (iii) respond to claims of a violation of the rights of third parties; (iv) respond to user comments or service inquiries; (v) protect our rights, property, or safety and the rights, property and safety of Services, our users or the public; or (vi) prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. However, myPlane will endeavor only to disclose information requested via a valid legal process and will endeavor to notify any user about whom we have disclosed information if possible.

3. Links to Other Websites

We frequently make content or services from other websites available to you from links located on the Sites. We may present links in a format that enables us to keep track of whether these links have been followed. In addition, you may opt to link your Account to your social media account, such as Facebook and Twitter, in accordance with your Account settings (which you may change at any time) and respective policies of these third parties. This Privacy Policy applies only to Sites and Services. We do not exercise control over third party services or other websites that provide information, or over banners or links from within Sites or Services. Your interactions with these third party services are governed by the privacy policy of the company providing it. These other sites and services may place their own cookies or other files on your computer’s browser, collect data or solicit personal information from you. Other websites and services follow different rules regarding the use or disclosure of Personal Information that you submit, and the collection and use of such information and access of any third party websites are subject to such third party’s privacy policy. We encourage you to read the privacy policies and other terms of such third parties before using their services.

4. Security

We understand the importance of privacy and security to our users and have made them a priority. myPlane uses a variety of industry-standard security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure and trains myPlane employees on privacy and security issues. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes, and we do not promise that your Personal Information or private communications will be protected from unauthorized disclosure or use. myPlane is not responsible for the actions of those who obtain your content in this manner. myPlane cannot guarantee your safety and security and you should be aware that submitting any information and using the Services is done at your own risk. Please do not provide any privileged information on Sites or when using Services.

5. Managing Your Privacy

We keep your data on your behalf and for your benefit. You can correct or delete your account information by following the instructions on Services or by e-mail at info(at)myplane.io. You may also email us to request for further assistance.

6. Jurisdiction

All information passed through myPlane is primarily handled in Finland, but may from time to time be handled in any country in which myPlane or its co-operating companies maintain facilities or operations. By using the Services, you agree that the handling of your personal information and any communication through the Services will be governed by the laws of Finland.

7. Changes to Privacy Policy

Our security and Privacy Policy are periodically reviewed and enhanced as necessary. This Privacy Policy might change as we update and expand the Services. We will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. We also encourage you to review this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of our policies, you may inquire regarding the same via email at info(at)myplane.io. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.

8. Contacting Us

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at info(at)myplane.io attn: Data Protection Officer, or via address Lapinlahdenkatu 16, 00180 Helsinki, Finland.

You have the right to make a complaint at any time to the Finnish supervisory authority for data protection issues (in Finnish: “tietosuojavaltuutetun toimisto”). We would, however, appreciate the chance to deal with your concerns as the first instance.

9. Data Retention

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your Personal Information for a longer period to enable us to comply with external reporting requirements and/or in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We maintain details of retention periods for different aspects of your Personal Information and regularly review to ensure we are in compliance with any limitation periods and record retention obligations that are imposed to us by applicable mandatory law.

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. In addition, you expressly understood and consent that we shall be entitled at our own discretion to aggregate all data in our Services into a representation of the collaboration as a whole, including, for clarity, any payment related information and possible ratings done within Services after anonymizing of all Personal Information (“Collective Data”). Such Collective Data, and for clarity all intellectual property rights thereof, shall be solely owned by us and our use of such Collective Data is not subject to confidentiality or limited in anyway by you, during the term of this Privacy Policy or after its termination.

10. Your Legal Rights

Under certain circumstances, you have rights under applicable data protection legislation in relation to your Personal Information.

(1) Request access to your Personal Information.

(2) Request correction of your Personal Information.

(3) Request erasure of your Personal Information.

(4) Object to processing of your Personal Information.

(5) Request restriction of processing your Personal Information.

(6) Request transfer of your Personal Information.

(7) Right to withdraw any consent you have given to us.

(8) Right to opt-out from receiving any marketing information from us (e.g. marketing messages).

If you wish to exercise any of the rights set out above, please send email to info(at)myplane.io, attn: Data Protection Officer, or via address Lapinlahdenkatu 16, 00180 Helsinki.

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within two (2) months. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you duly updated.