# Privacy and Cookie Policy Last Updated: June 23, 2022 ### Introduction At FLYR, Inc., we care about your privacy and want you to be familiar with how we collect, use and share information. This Privacy and Cookie Policy (the “Policy”) describes our practices in connection with the Personal Data that we collect, use and share through the FLYR’s website (currently available at flyrlabs.com) and any successor website, on both desktop and mobile web browsers (the “Website”); and through HTML-formatted email messages that we send to you. By providing Personal Data to us, you agree to the terms and conditions of this Policy and to us collecting, holding, using and disclosing your Personal Data in accordance with it. This Privacy and Cookie Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy and Cookie Policy. ### 1. The Data We Collect About You As used in this Policy, “Personal Data” includes (i) any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, email address and telephone number; or (ii) an opinion about an identified individual or an individual who can be reasonably identified from the opinion, regardless of whether such opinion is true. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows: - **Identity Data** includes first name, last name, username or similar identifier, title, or social media account ID. - **Contact Data** includes billing and/or physical address, email address and telephone numbers. - **Employment Data** includes data about your professional life such as Curriculum Vitae or cover letter. - **Marketing and Communications Data** includes your preferences in receiving marketing from us and our third parties and your communication preferences. - **Technical Data** includes internet protocol (IP) address, your Media Access Control (MAC) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, your interactions with our Website, and other technology on the devices you use to access this Website. - **Usage Data** includes information about how you use our Website. ### 2. How Your Personal Data is Collected **We collect information about you in the following ways:** **Information You Give Us Directly.** This includes: - Identity and Contact Data you provide to us when you correspond with us by phone, email or otherwise; and - Marketing and Communications Data, such as your preferred means of communicating with us, when you voluntarily provide it. **Information We Receive from Social Networking Sites.** Our Website include(s) interfaces that allow you to connect with social networking sites (each a “SNS”). If you connect to a SNS through our Services, you authorize us to access, use and store the information that you agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS. **Information We Receive from Other Sources.** We may also collect information about you from the following other sources: 1. Technical Data from analytics providers such as Google based in the United States; 2. Identity and Contact Data from data brokers and aggregators. 3. Identity and Contact Data from your friends and other people with whom you are connected on social media platforms; **Information We Collect Automatically.** We automatically collect Technical and Usage Data about you and your computer or mobile device when you access the Services from your computer or mobile device’s web browser. ### 3. Cookies **What Are Cookies?** We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Services. ### 4. Pixel Tags We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Services to track the actions of users on our Services. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ Personal Data. ### 5. Do Not Track Signals We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit [www.allaboutdnt.com](http://www.allaboutdnt.com/). ### 6. Using Your Personal Data We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances: - Where we need to perform the contract we are about to enter into or have entered into with you. - Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. - Where we need to comply with a legal obligation. ### 7. Sharing Your Personal Data We may share your Personal Data as follows: - **Third Party Advertisers.** We may share with your consent Personal Data with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. - **Affiliates.** We may share some or all of your Personal Data with our affiliates, in which case we will require our affiliates to comply with this Policy. ### 8. Aggregated/Anonymous Data When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party. ### 9. Third Party Sites Our Services may contain links to third party websites and features. This Policy does not cover the privacy practices of such third parties. ### 10. International Data Transfer Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. ### 11. Security We have put in place appropriate organizational, technical and administrative measures to protect Personal Data within our organization. ### 12. Retention We will only retain your Personal Data as long as reasonably required for you to use and provide you with the Services unless a longer retention period is required or permitted by law. ### 13. Our Policy on Children Our Website is not directed to children under 16. ### 14. Sensitive Personal Data We do not collect and ask that you please do not send us or otherwise disclose to us through the Website any sensitive Personal Data. ### 15. Your Rights Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. Please click on the links below to find out more about these rights: - [Request access to your Personal Data](https://flyr.com/privacy-and-cookie-policy/#request-access) - [Request correction of your Personal Data](https://flyr.com/privacy-and-cookie-policy/#request-correction) - [Request erasure of your Personal Data](https://flyr.com/privacy-and-cookie-policy/#request-erasure) - [Object to processing of your Personal Data](https://flyr.com/privacy-and-cookie-policy/#object-to-processing) ### 16. Complaints We are committed to resolve any complaints about our collection or use of your Personal Data. ### 17. Contact Information We welcome your comments or questions about this Policy. You may contact us at [compliance@flyrlabs.com](mailto:compliance@flyrlabs.com) or: Attn: Compliance Team FLYR, Inc. 160 Spear St San Francisco, CA 94105 USA ### 18. Glossary **LAWFUL BASIS** **Legitimate Interest** means the interest of our business in conducting and managing our business.