Privacy Policy

Last Updated: October 28, 2021

 

AirMatrix Inc. (“AirMatrix”, “we”, “us”) has created this Privacy Policy (the Privacy Policy”) in order to set
out how we collect, process, and disclose information that identifies or can be used to identify a living
individuals (“Personal Information”). This Privacy Policy applies to Personal Information collected
through our website, www.airmatrix.ca, including its subpages (collectively, the “Website”), through our
software applications and the AirMatrix platform (the “Platform”) and in the course of providing access
to our products, software and services (collectively, all of the foregoing the “Services”). Our Services enable
our users (referred to herein as “End Users”) to access airspace and conduct flight on our mapped aerial highways,
all as further described and subject to our user agreements.


Compliance with privacy laws is important to us. We do not actively collect Personal Information for the
purpose of selling or marketing that Personal Information to third parties. In other words, we do not sell
customer lists. Personal Information may be collected about users and visitors to the Website, as well as
our customers and their end users who interact with our Services.


By visiting our Website or using the Services in any manner, you acknowledge that you accept the practices
and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of
your Personal Information in accordance with this Privacy Policy.

1. OVERVIEW

1.1 A Note about Children

Our Services are intended for use by qualified drone operators; not minors. We do not intentionally
gather Personal Information (defined in Section 2 of this Privacy Policy “Scope”) from children. If a child
under 13 submits Personal Information to AirMatrix and we learn that the Personal Information is the
Personal Information of a child under 13, we will attempt to delete the Personal Information as soon as
possible. If you believe that we might have any Personal Information from a child under 13, please contact
our Privacy Officer at privacy@airmatrix.ca.

1.2 International Users

AirMatrix is a Canadian resident corporation. If you are a nonU.S. or nonCanadian user of the Services,
you acknowledge and agree that your Personal Information may be processed for the purposes identified
in this Privacy Policy. In addition, your Personal Information may be processed in the country in which it
was collected and in other countries, including the United States and Canada, where laws regarding
processing of Personal Information may be less stringent than the laws in your country. By providing your
data, you consent to such transfer. If you are in the UK or EEA please see specific terms which apply to
you further below.

1.3 Lawful Processing

We process Personal Information only to the extent necessary for the purposes described in this Privacy
Policy. We set out below the type of Personal Information we collect and how we use such Personal
Information. Except as set forth in this Privacy Policy, your Personal Information will not be used for any
other purpose without your consent. You may withdraw your consent to our processing of your Personal
Information at any time. However, withdrawing consent may result in your inability to continue using the
Services.

2. SCOPE

This Privacy Policy does not apply to the practices of companies that we do not own or control, to
individuals that we do not employ or manage, or to any technology (such as unmanned aerial vehicles
(otherwise referred to as multicopters, drones and similar) and their transmitters and receivers) provided
by third parties, including without limitation third party hardware and third party software (“Third Party
Technology”). You are responsible for ensuring that you have obtained the necessary authorizations and
consents for any Personal Information you make available to us for use in accordance with this Privacy
Policy. In particular, our customers represent and warrant to AirMatrix that they have the necessary rights
under applicable law or have obtained the necessary consents from each End User whose Personal
Information is provided by that customer to AirMatrix in order to allow AirMatrix to use, disclose and
otherwise process such Personal Information for the purposes described in this Privacy Policy in the
manner described in this Privacy Policy.

3. COLLECTION OF PERSONAL INFORMATION

3.1. Basic Account Information

When you register for the Platform or create an End User account, AirMatrix collects your name, email
address, business phone number and business address (“Account Information”). We may also collect
payment credentials or related information to allow End Users to pay AirMatrix for access and use of the
Platform and Services.

3.2. Information Collected Through the Platform

Our Platform may collect and use diagnostic and technical data that is gathered periodically to enable you
to create and manage your AirMatrix account and to improve the overall quality and user experience of
the Services (“Platform Usage Data”).

3.3. Website Visitors

Our Website may contain informational links to other websites that are not owned or controlled by us.
We are not responsible for the privacy practices of such other websites, and such websites are excluded
from the terms of this Privacy Policy.

3.4 Service Users

When you use the Services, we may collect Personal Information intended to enhance flight safety and
regulate traffic flow. The Personal Information collected includes the first and last name, address, phone
number, identification documentation, organization, drone operator registration information and aircraft
type. When End Users use the Services, we may also collect flightspecific information such as aircraft
battery level, location, destination and sensor information (the “Flight Data”) which is associated with the
Personal Information of the End User who owns or operates the applicable aircraft.

4. USE OF YOUR PERSONAL INFORMATION

AirMatrix uses Personal Information to:

  • authenticate access to your AirMatrix account;
  • verify End User’s identities for the purposes of tracking for airspace safety and reporting on air traffic incidents involving an End User’s aircraft(s).
  • send technical notices, updates, security alerts and support and administrative messages;
  • provide and deliver the Services that End Users request and pay for;
  • provide customer service, support and otherwise communicate with End Users;
  • prevent fraudulent transactions, unauthorized access to the Platform or Services, and other illegal activities;
  • complete transactions, and send you related information to the relevant transaction participants, including confirmations and invoices;
  • communicate with End Users about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about AirMatrix and our select partners;
  • personalize and improve the Services and otherwise customize your experience while using the Services;
  • monitor and analyze trends, usage, and activities in connection with the Services;
  • conduct business and contractual relationships that we have with various persons and companies (such as customers, suppliers, partners and employees); and
  • for other purposes which we will notify you about and seek your consent.

5. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION

5.1. Storage and Transfer

AirMatrix processes and stores its data, including Personal Information, on servers located in Canada.
AirMatrix also transfers data to thirdparty service providers, including the service providers described in
Section 5.2 of this Privacy Policy (“SubProcessors”). By submitting Personal Information or otherwise
using the Services, you agree to this transfer, storing or processing of your Personal Information in Canada.
You acknowledge and agree that your Personal Information may be accessible to law enforcement and
governmental agencies in Canada under lawful access regimes or court order.

5.2. Sub-Processors

To support AirMatrix in delivering the Services, AirMatrix engages thirdparty service providers as sub
processors. This section identifies our subprocessors, describes where they are located, lists the services
they provide to us and identifies the type of Personal Information processed. Our business needs may
change from time to time and AirMatrix will periodically update this Privacy Policy to include additions
and removals to our list of subprocessors.


Service ProviderTypes of PI ProcessedProcessor ActivitiesLocation
Amazon Web ServicesName, address, phone
number, identification
documentation,
organization, drone
operator registration
information, aircraft
type, aircraft battery
level, location,
destination and sensor
information.
Cloud hosting, databaseUSA
GithubName, address, phone
number, identification
documentation,
organization, drone
operator registration
information, aircraft
type, aircraft battery
level, location,
destination and sensor
information.
Code hostingUSA
DockerName, address, phone
number, identification
documentation,
organization, drone
operator registration
information, aircraft
type, aircraft battery
level, location,
destination and sensor
information.
ContainerUSA
KubernetesDocker imagesContainer clustersUSA
JenkinsNoneBuild, test and deploy the ServicesUSA

6. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES

6.1. Service Providers and Business Partners

We may from time to time employ third parties to perform tasks on our behalf and we may need to share
Personal Information (including Account Information) with them to perform those tasks. Unless we tell
you differently, such third parties do not have any right to use the Personal Information we share with
them beyond what is necessary for them to provide the tasks and services on our behalf. The third parties
we currently engage includes third party companies and individuals employed by us to provide certain
capabilities within the Services and for certain general business functions, including the provision of
maintenance services, database management, payment processing, and general improvement of the
Services, including the SubProcessors.

6.2. Business Transfers

If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business,
enter bankruptcy, or go through some other change of control, Personal Information may be made
available or otherwise transferred to the new controlling entity, where permitted under applicable law.
Your Personal Information may also be transferred in connection with due diligence for any such
transactions. In all cases, if any such transactions occur, your Personal Information will remain subject to
the restrictions and protections set forth in this Privacy Policy.

6.3. With Your Consent

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will
notify you and/or obtain consent as required under applicable privacy laws.

6.4. As Required by Law

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other End Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:

  • satisfy any applicable law, regulation, legal process or governmental request (including in pursuant to subpoenas, civil investigative demands, or similar processes); enforce our contracts or user agreement, including investigation of potential violations hereof; and
  • detect, prevent, or otherwise address fraud, security or technical issues

The above may include exchanging information with other companies and organizations for fraud protection, spam/malware prevention and know-your-customer purposes. Notwithstanding the general terms of this policy, the collection, use, and disclosure of Personal Information may be made outside of the terms herein to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders. 

7. RETENTION

We will keep your Personal Information for the longer of: i) 6 months [from the end of our contractual relationship with you]; or ii) for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, nonpersonallyidentifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

8. ACCESS, CORRECTION AND ACCURACY

You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another
End User. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.

 

We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.

9. RESIDENTS OF THE EUROPEAN ECONOMIC AREA ("EEA") AND THE UK

If you are a resident of the EEA or the UK, you have certain data protection rights. AirMatrix takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018).

 

If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from our systems, please contact us using the contact information set out in Section 12 of this Privacy Policy “Contact Details”. Note that where we act as a data processor on behalf of our customers, you will be required to contact the data controller directly to exercise your rights.

 

In certain circumstances, where we act as data controller, you have the following data protection rights:

  • Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
  • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right
    to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights
    and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling
    legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not
    want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine
    readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with
    you.
  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests.

 

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority. If you wish to
exercise any of the rights set out above, please contact us using the contact details in Section 12 of this
Privacy Policy “Contact Details”.

10. CALIFORNIA PRIVACY RIGHTS

This section provides additional details about the Personal Information we collect about California
consumers and the rights afforded to them under the California Consumer Privacy Act (the CCPA).


For more information about the Personal Information AirMatrix has collected over the last 12 months,
please see Section 3 of this Privacy Policy “Collection of Personal Information”. We collect this Personal
Information for commercial purposes described below. AirMatrix does not sell (as that term is defined in
the CCPA) the Personal Information we collect.


Subject to certain limitations, the CCPA provides California consumers the right to request to know more
details about the categories or specific pieces of Personal Information we collect about them (including
how we use and disclose this Personal Information), to delete their Personal Information, to opt out of
any “sales” of Personal Information that may be occurring, and to not be discriminated against for
exercising these rights.


California consumers may make a request pursuant to their rights under the CCPA by contacting us at the
contact information in Section 12 of this Privacy Policy “Contact Details”. We will verify your request using
the information (including Personal Information) associated with your account, if available, including
email address. Government identification may be required. Consumers can also designate an authorized
agent to exercise these rights on their behalf.

11. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to
the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material
changes or changes in the way we use Personal Information, we will notify you by posting an
announcement on our Website or Platform or sending you an email prior to the change becoming
effective. You are bound by any changes to the Privacy Policy when you use the Services after such
changes have been first posted.


You will not have to pay a fee to access your Personal Data (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 Data (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.

12. CONTACT DETAILS

Questions regarding this Privacy Policy, AirMatrix’s privacy practices or your Personal Information should
be directed to our Privacy Officer, Ayaan Haider by:
Post to: AirMatrix Inc. Ontario 100 College Street, Suite 250, Toronto, ON Canada M5G 1L5
or
Email to: privacy@airmatrix.ca