Privacy Policy

ELROY AIR, INC.
GLOBAL PRIVACY POLICY
Last Updated: July 28, 2023

Elroy Air, Inc. and its affiliates (“Elroy Air”) respect your privacy and work hard to protect it. This Global Privacy Policy (“Policy”) explains:

what information we collect about you;
how we use and share that information; and
how we protect your information and your rights and choices regarding its collection and handling.

This Policy applies to all information collected or submitted on the Elroy Air website (elroyair.com) as well as any other information we may collect and process in the course of conducting our business (collectively, the “Services”). By accessing the Services, you consent to our collection and use of your information as described in this Policy.

This Policy includes the following sections; please click through to learn more:

Policy Overview
Types of Information We Collect About You
How We Use and Share Collected Information
How We Retain and Protect Collected Information
Your Choices
Additional Information for Users in Certain Jurisdictions
Changes to this Policy
Contact Us

Data Controller: The data controller for the information you provide or that is collected through the Services is:

Elroy Air, Inc.
415 E Grand Ave. Suite 201
South San Francisco, CA 94080

Important Note Regarding Minors: By using the Services, you represent that you are at least 18 years old. Individuals under 18 (or the applicable age of majority in the place where the Services are accessed) may not use our Services except through their parents or guardians. We do not knowingly collect any personal information from minors, except from their parents or guardians. If we become aware that an individual submitting information is under 18, we will delete such information as soon as reasonably practicable. If you become aware that a minor has provided us with personal information, please contact us as indicated in the “Contact Us” section of the Policy.

Policy Overview

Elroy Air collects information from users of our Services in order to provide the Services and enhance the user experience on our website and other online platforms.

The practices described in this Policy are subject to applicable laws in the places in which we operate. This means that we only engage in the practices described in this policy in a particular country or region if permitted under the laws of those places. In addition, where specified, certain aspects of this Policy only apply to particular geographic regions. Please contact us if you have questions regarding our practices in your country or region.

Types of Information We Collect About You

Information You Provide to Elroy Air

Certain parts of our website or other Services may allow you to provide personal information to us voluntarily: for example, you may provide us with your name, job title, and contact information if you contact us through the website. You may also provide us with personal information when you partner with us on one of our projects, submit an inquiry to us, or correspond with us by email, mail, or otherwise, or attend one of our events. This may include, for example, your nationality and visa status for purposes of complying with applicable export control regulations.

We use this information primarily to respond to your inquiry or request, to communicate with you about such matters, to comply with applicable laws and regulations, and to manage and administer our projects and opportunities.

We only require you to provide information that is necessary for us to perform the function for which you have provided it, although you can choose to provide us with additional information that may enhance your experience with our Services.

If you are providing personal information in connection with a job application, please review the Privacy Policy of our third party partner to which you’re linked.

Information Elroy Air Collects When You Access Our Services

In addition to any information you provide to us voluntarily, we also collect the following additional information automatically when you access our Services:

Your Internet Protocol address
Referral information (such as whether you arrived at our website from a search engine)
Web pages you access and actions you take on the Service
Browser type
Information about your device, including the type of mobile device or computer and operating system
Date and length of your visit

In addition, when you complete one of our online forms, communicate with us through our Services, communicate with us on a third party (e.g., social media) platform, or otherwise contact us by email, phone, or text, or visit one of our sites, we may collect and store certain information about these communications, including:

Date, time, and contents of the message
Your name and contact information
Your affiliation or company information
Type of communication
Purpose of the communication, and the action we took in response to your request
Any action you take when you receive a communication (for example, whether you register to attend an event that we offer, or request to receive documentation)
Where applicable for compliance with law, your nationality and/or immigration status

Cookies

Cookies are small files created by your device when you access and use our Services. They allow the website to recognize your device and store information about your preferences or past actions. They ease navigation, and increase the user-friendliness of websites and applications. Cookies can also be used to determine whether there has been any contact between us and your device in the past.

We use cookies to optimize the design of our website and other online services. This enables us to provide content that is more accurately suited to our users’ needs, and, in doing so, improve our services. We use only strictly necessary cookies, and performance cookies. Specifically, we use cookies for:

Performing functions necessary for the operation of the website
Improving website performance and delivery optimization
Improving user interaction with our services, including by tracking user preferences, traffic and referral information, user IP address and geographic location, average time on site, and other usage metrics

These metrics and analytics are collected and analyzed on our behalf by our third-party partner, Google Analytics. Please review Google’s privacy and terms.

We have not sold information derived using cookies to third parties and we will not sell any of this information to third parties. Any use by our analytics partner is subject to their privacy policy and terms of use.

How We Use Collected Information:

The information we collect is used as described above and for the following purposes:

To Provide, Maintain, and Improve Our Services: This includes, for example, providing information about our company, developing new features, authenticating users, and sending project and service updates and administrative messages.
To Personalize and Improve the Services: This includes providing or recommending features, content, social connections, and referrals.
To Perform Internal Operations: This includes, for example, preventing fraud and abuse of our Services, troubleshooting software bugs and operational problems, conducting data analysis, testing and research, and monitoring and analyzing usage and activity trends.
To Comply with Applicable Laws and Regulations. This includes, for example, processing personal information for purposes of complying with U.S. Export Control regulations, including the Export Administration Regulations (EAR).
To Communicate with You: This includes, for example, using your contact information in order to send you email or other communications regarding the exciting new things happening at Elroy Air.

We may share your information with third parties as follows:

With vendors, consultants, advisors and other service providers who need access to such information to carry out data processing or other work on our behalf.
In response to a request for information issued by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process.
In connection with, during negotiations of, or as part of the implementation of any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
When needed to pursue or defend legal claims or respond to lawful subpoenas or warrants.

Legal Bases for Processing

We process your personal information with your consent, where doing so is necessary for the execution or performance of a contract, to protect your vital interests or those of another individual, to comply with our legal obligations, and where doing so is necessary for the purposes of our legitimate interests or the legitimate interests of a third party. Our legitimate interests include:

Providing and improving our Services.
Protecting our company, our employees, our Services, our users, and the public.
Detecting and preventing crime, fraud, or misuse.
Promoting and marketing our Services.
Ensuring compliance with applicable laws and our Terms of Service.

Cross-Border Transfer of Information

To facilitate our operations we may transfer, store, and process your information internally and with our partners and service providers based around the world. Laws in some countries may differ from the laws applicable to your country of residence and may not provide an equivalent level of protection. Where required, we have implemented appropriate solutions to protect cross-border transfers.

You may have been directed to our Services through a third-party website or the website of another affiliated entity. In addition, the Services contain links (for example, to view another service provider) and social networking buttons (for example, Facebook or Twitter) that link to other websites or services that are not owned, operated or controlled by Elroy Air. We have no control over and are not responsible for the data collection and/or handling practices of such other websites. The display through the Services of a link to a third party’s website or app does not imply our endorsement of such website or app.

We encourage you to be aware when you leave our Services and to read the privacy statements of each website or app on which you land after you click on a link or social networking button. This Policy does not address the information practices of any third party or other affiliated entity. The inclusion of a link on the Service(s) to another website or service does not imply endorsement of that party’s data handling practices and does not imply that their practices are covered by this Policy.

How We Retain and Protect Collected Information

Security

We limit access to information about our users only to those employees and authorized parties who reasonably need access to the information in order to perform their job responsibilities. We use commercially reasonable technical, organizational, and administrative measures to protect against unauthorized or unlawful access or processing and against accidental loss, theft, disclosure, copying, modification and destruction, or damage. Nonetheless, we cannot guarantee that transmissions of your information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to causes beyond our control. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately as detailed in the Contact Us section, below.

Retention

We will retain the information we collect about you for as long as necessary to provide the Service or comply with a legal request. We will anonymize or securely dispose of the information in our custody after it is no longer needed so that it can no longer be attributed to a particular individual.

In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal, and auditing obligations.

Your Choices

You have choices about the types of information we collect and share about you.

Use of Cookies

Most browsers automatically accept cookies. You can set your internet browser preferences not to accept cookies. The exact instructions for this can be found in the manual or help documentation for your browser. You can delete cookies already on your device at any time. To learn more about the available cookie settings for a particular browser or device, please refer to the following links:

Please note that blocking or disabling certain cookies may interfere with your ability to use some parts of our Services. While you may disable the usage of cookies through your browser settings, our Services do not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted.

Individual Rights

To the extent required by applicable law, we provide you with the ability to access, correct, export, delete, withdraw consent, object to the processing of, or suspend processing of your personal information. These functions will either be available within our Services or you can contact us to submit a request. We will respond to your request in accordance with applicable regulations and upon presentation of appropriate proof of identity. Please note that some of the information we collect is required and removal of it may render you ineligible to use our Services.

Additional Information for Users in Certain Jurisdictions

Europe and the United Kingdom

Cross-Border Transfers

Information collected within the European Economic Area (“EEA”) may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store, and process your personal information outside of the EEA, we have put in place appropriate safeguards to ensure an adequate level of protection to the transferred information in accordance with applicable law. To obtain information about safeguards we use for cross-border transfers, please contact us.

Data Protection Officer

Elroy Air’s data protection officer can be contacted at: legal@elroyair.com or

Elroy Air, Inc.
Attn: Legal Department
415 E Grand Ave. Suite 201
South San Francisco, CA 94080.

Right to Complain to a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal information in a manner inconsistent with your rights.

California Privacy Rights

The following disclosures are made pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”).

We have not sold personal information to third parties and we will not sell your personal information to third parties.

The below chart reflects the categories of personal information we have collected from California consumers over the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, and the categories of third parties with whom we shared that information.

Categories of Personal Information Collected	Sources of Collection	Business/Commercial Purpose for Collection	Third Parties Receiving Personal Information
Personal identifiers including your name, alias, signature, address, phone number, email address.	Directly from the consumer	When you interact with us through our website or otherwise, we may collect your personal information in order to respond to an inquiry or request, to communicate with you about such matters, to comply with applicable laws and regulations, and to manage and administer our projects and opportunities.	Vendors, consultants, advisors, and other service providers
Other personal information such as your nationality and immigration status.	Directly from the consumer	We may be required to collect from you information regarding your national origin and immigration status to comply with applicable export control laws and regulations.	N/A
Internet and other network activity information including online identifiers such as your IP address or device identifier, browsing history, search history, and information about your interactions with websites, applications, or advertisements.	Third-party internet analytics tools, e.g., Google Analytics	We use third party services to collect IP addresses and other information from visitors to our website in order to improve website performance and user interaction with our services.	Vendors, consultants, advisors, and other service providers

“Consumers” (including You) have certain rights under the CCPA, subject to applicable limitations. These rights include:

The right to know about what personal information collected about You and the categories of third parties with whom we shared personal information, as well as the right to access it;
The right to delete personal information collected about you;
The right to correct any inaccurate personal information;
The right to opt-out of the sharing of personal information;
The right to non-discrimination for exercising any rights under the CCPA; and
The right to limit the use and disclosure of “Sensitive Personal Information,” for example your social security number, financial account information, and genetic data.

If you wish to inquire regarding the exercise of these rights, please submit a request to legal@elroyair.com.

Right to Know

California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, disclosed, and sold during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their personal information. You can submit a request to legal@elroyair.com. The personal information that we use to verify your identity will not be used for any other purpose.

Right to Delete

California residents have the right to request deletion of the personal information we have collected from them or maintained about them. You can submit a deletion request to legal@elroyair.com. You will need to provide us with certain information that will be used to verify your identity. The personal information that we use to verify your identity will not be used for any other purpose.

We do not discriminate against California residents who exercise their CCPA privacy rights.

Changes to this Policy

We change and update this Policy from time to time. The effective date at the top of the policy will indicate when it was last modified. If we make significant changes in the way we treat your personal information, or to the Policy, we will provide you the updated Policy through the Services or by some other means, such as an email. We encourage you to periodically review the Policy for the latest information on our privacy practices.

YOUR CONTINUED USE OF THE SERVICES AFTER WE HAVE NOTIFIED YOU OF THE CHANGES IN ACCORDANCE WITH APPLICABLE LAW WILL CONSTITUTE YOUR CONSENT TO THE CHANGES.

Contact Us

If you have any questions about this Policy, please contact us at legal@elroyair.com.

You may also reach us at the following address:

Elroy Air, Inc.
Attn: Legal Department
415 E Grand Ave. Suite 201
South San Francisco, CA 94080